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They are not amounts paid in respect of managerial services in connection with the direction or supervision of business activities. ... The Queen, [1991] 1 CTC 197), aff'd [1991] 2 CTC 221 wherein the Federal Court Trial Division examined the application of paragraph 212(1)(a) in the context of a portfolio management company and the court explained, “(g)enerally speaking, a management or administration fee is an amount paid in respect of managerial services in connection with the direction or supervision of business activities...”. ...

The Plan provided that XXXXXXXXXX might, in connection with the granting of such options, impose certain conditions as to the ownership of the Restricted Shares. ... The taxpayer posted security for the tax liability in connection with such taxable capital gain. ...

This is evident from the various dictionary definitions of the word “royalty” when used in connection with a sum payable. ... The Distribution Agreement does not contemplate an extensive use of the trade-mark, but only limited use in connection with the distribution, promotion and advertising of the product granted under the gratuitous license to use the trade-mark for the commercialization of the Product in Canada. ...

They import such meaning as "in relation to", "with reference to" or "in connection with". The phrase "in respect of" is probably the widest of any expression intended to convey some connection between two related subject matters. ...

It implies physical connection or physically joined to, yet physical connection may be dispensed with, and things may be annexed without being in actual contact, when reasonably practicable. ...

We have previously indicated, that 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 the fishermen's business and a reserve, by acting as an intermediary between the fishermen 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. ...

Its assets consist mainly of inventory and accounts receivable arising in connection with its business activities, land and building which it uses in carrying on its business and goodwill associated with the business.  ... In addition, you have identified several areas which you believe may be of potential concern to the Department in connection with this particular series of transactions and have also requested our views concerning these areas. ...

The services enable the Landcos to acquire raw, undeveloped land, make rezoning applications for development, subdivide the property, fully service the property by putting in place utility connections such as water, sewage, hydro, gas, telephone and build roads so as to provide fully serviced lots available for sale individually or en bloc to building contractors. ...

Therefore, there is a causal connection between the foreign tax paid and the adjustment to claim the foreign tax credit, regardless of whether the adjustment includes an addition to income under the provisions of section 110.5. ...

Therefore, in our view, context requires that the reference to "interest determined with reference to any change in value of any property of the debtor" in subparagraph 6(b) of Article XI of the Treaty be read broadly so as to capture interest which is computed by reference to the price of a commodity, where there is a link or connection between the commodity price and the value of any property of the debtor. ...