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It may not always be easy to decide whether an expense has so arisen but it seems to me that the words "in the course of" in section 11(1)(cb) are not a reference to the time when the expenses are incurred but are used in the sense of "in connection with" or "incidental to" or "arising from" and refer to the process of carrying out or the things which must be undertaken to carry out the issuing or selling or borrowing for or in connection with which the expenses are incurred. ... That is, there must be a clear connection between the amount sought to be deducted and the issuance of the shares. Paragraph 16 of IT-341R3 where a corporation has expenses that are incurred in the course of an issuance or sale of shares in the capital stock of the corporation the following expenses would be deductible in the year in which they are incurred: (a) legal fees in connection with the preparation and approval of a prospectus pertinent to the issuance or sale of shares, units, or interests; (b) accounting or auditing fees in connection with the preparation of reports on financial statements and statistical data for inclusion in, or for presentation with, the prospectus; (c) the cost of printing the prospectus, new share, unit, or interest certificates, etc; (d) registrars' or transfer agents' fees; and (e) filing fees charged by any public regulatory body which requires the filing of a prospectus for acceptance The pre-amble to subsection 20(1) provides as follows: 20(1) Notwithstanding paragraphs 18(1)(a), (b) and (h), in computing a taxpayer's income for a taxation year from a business or property, there may be deducted such of the following amounts as are wholly applicable to that source of such part of the following amounts as may reasonably be regarded as applicable thereto: (emphasis added) Subsection 138(2) of the Act provides that the income or loss of a multinational life insurer from carrying on an insurance business shall be computed with reference only to insurance businesses carried on in Canada: (2) Notwithstanding any other provision of this Act, where a life insurer resident in Canada carries on an insurance business in Canada and in a country other than Canada in a taxation year (a) its income or loss for the year from carrying on an insurance business is the amount of its income or loss for the year, computed in accordance with this Act, from the business in Canada; and Section 4 of the Act provides, more generally, that income or loss from any source is to be computed as if the particular source were a taxpayer's only source of income. ...

It may not always be easy to decide whether an expense has so arisen but it seems to me that the words "in the course of" in section 11(1)(cb) are not a reference to the time when the expenses are incurred but are used in the sense of "in connection with" or "incidental to" or "arising from" and refer to the process of carrying out or the things which must be undertaken to carry out the issuing or selling or borrowing for or in connection with which the expenses are incurred. ... That is, there must be a clear connection between the amount sought to be deducted and the issuance of the shares. Paragraph 16 of IT-341R3 provides that where a corporation has expenses that are incurred in the course of an issuance or sale of shares in the capital stock of the corporation the following expenses would be deductible in the year in which they are incurred: (a) legal fees in connection with the preparation and approval of a prospectus pertinent to the issuance or sale of shares, units, or interests; (b) accounting or auditing fees in connection with the preparation of reports on financial statements and statistical data for inclusion in, or for presentation with, the prospectus; (c) the cost of printing the prospectus, new share, unit, or interest certificates, etc; (d) registrars' or transfer agents' fees; and (e) filing fees charged by any public regulatory body which requires the filing of a prospectus for acceptance The pre-amble to subsection 20(1) provides as follows: 20(1) Notwithstanding paragraphs 18(1)(a), (b) and (h), in computing a taxpayer's income for a taxation year from a business or property, there may be deducted such of the following amounts as are wholly applicable to that source of such part of the following amounts as may reasonably be regarded as applicable thereto: (emphasis added) Subsection 138(2) of the Act provides that the income or loss of a multinational life insurer from carrying on an insurance business shall be computed with reference only to insurance businesses carried on in Canada: (2) Notwithstanding any other provision of this Act, where a life insurer resident in Canada carries on an insurance business in Canada and in a country other than Canada in a taxation year (a) its income or loss for the year from carrying on an insurance business is the amount of its income or loss for the year, computed in accordance with this Act, from the business in Canada; and Section 4 of the Act provides, more generally, that income or loss from any source is to be computed as if the particular source were a taxpayer's only source of income. ...

The employment duties would also have to be considered to determine if, as required under Guideline 4, they were in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserves. ... An organization might be controlled by a few Indians who happen to live on reserve and may represent a particular segment of Indians on reserve, but that does not establish the same connection to a reserve that is established where the band itself controls the organization. ... In both of these examples, the income is exempt because there is a connection to the reserve. ...

Debtor has not provided any information in connection with the use by it of funds obtained under the said existing term facility. 3. ... Similarly, any hedging transactions in connection with the Notes must also be treated independently. ... Moreover, Debtor has not provided any information in connection with the use by it of funds obtained under the said existing term facility. ...

Paragraph 14 of IT-143R3, entitled "Meaning of Eligible Capital Expenditure" states that: "...incorporation expenses and similar expenses incurred in the setting up of a new corporation or in connection with an amalgamation of two or more corporations, as well as expenses incurred in connection with the reorganization of the affairs of a corporation (including the costs of supplementary letters patent), are "eligible capital expenditures" if they meet the requirements of that definition in subsection 14(5)... ... Accordingly, if expenses are paid by a parent company on behalf of its subsidiary in connection with the issuance of shares by its subsidiary, they are not deductible by the parent company under paragraph 20(1)(e). ...

In concluding that the parking garage and the hotel were two separate buildings, the TCC relied on the following factors: No physical connection between the two buildings; Both businesses have their own economic life and sources of income; The parking garage could stand on itself; and The parking garage did not form an integral part of the hotel. The listed factors suggest that the TCC relied mainly on the degree of physical connection or integration of the two assets in concluding that the garage and the hotel were separate buildings. In the case at hand, there is a physical connection and integration between condo #1 and the Parking Lots, which we find as being determinative in concluding that they form one building. ...

During their XXXXXXXXXX taxation year, CFA1, CFA2, CFA3 and CFA4 performed research and development services (“R&D Services”), totalling approximately USD $XXXXXXXXXX in connection with XXXXXXXXXX held by Canco. 8. ... It is our understanding that the Taxpayer’s argument is to the effect that the R&D Services provided to Canco should be considered to be services performed in connection with the sale of goods under the terms of paragraph 95(3)(b), or, alternatively, be part of the manufacturing or processing of property, and as such subject to the exception provided in paragraph 95(2)(d). Concerning the scope of paragraph 95(3)(b), it has been our longstanding position that the phrase “services performed in connection with the (...) sale of goods” is limited to services that are directly related to the sales function (in this respect, see for example documents 9729770, 2002-0123755 and 2013-0497361I7). ...

In this case, the connection between the interest earned and income earned from production and processing described in Regulation 1204(1)(b)(ii) is too remote to include the interest in resource profits. ... In effect, the connection between the interest income and mining activities was found to be too remote. ... The Court found that there was sufficient inter-connection or integration with the business of production of silver that a gain from hedging activities could be considered to be income from that business to the extent that it corresponds to actual production. ...

In addition, the limited weight that an on reserve customer would otherwise carry as a connecting factor will not be recognized if it can reasonably be considered that one of the main purposes for the location of the customer on reserve is to serve as a connection between an Indian Fisher's business and a reserve, by acting as an intermediary between an Indian Fisher and the actual fish buyers who are located off reserve. ... Guideline 4 requires a) that the employer is resident on a reserve; b) that the employer is an Indian band which has a reserve, or a tribal council representing one or more Indian bands which have reserves, or an Indian organization controlled by one or more such bands or tribal councils, if the organization is dedicated exclusively to the social, cultural, educational, or economic development of Indians who for the most part live on reserves; and c) that the duties of the employment are in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserves. ... A7 A fishing licence held in connection with a fishing business is an eligible capital property in respect of the fishing business and, therefore, the rules in subsection 14(1) of the Act apply. ...

Podor 18th Floor, 18-46 Place de Ville, Tower B Ottawa, ON K1A 0L5 2015-058303 Registered Education Savings Plan (“RESP”) We are responding to your correspondence dated April 23, 2015 wherein you requested clarification on the tax consequences of in-kind transactions in connection with a trust governed by a registered education savings plan (“RESP trust”). ...