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In a previous opinion, we had noted 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. ...

These issues have arisen in connection with an audit of XXXXXXXXXX. The facts as we understand them are as follows: XXXXXXXXXX GIC 1. ...

As you know, A Co's representative wrote to us on July 7, 1999 in connection with this issue and we advised him that since the issue is currently under review by a tax services office, his correspondence would be referred to you. ...

Raisons: In such a case, the capital invested by the taxpayer (marketable securities) was used by the foreign affiliate to earn FAPI such that there is a direct causal connection between the transaction of investing in the foreign affiliate and the FAPI income of the foreign affiliate pursuant to subparagraphs 152(4)(b)(iii) and 152(4.01)(b)(iii). ...

Paragraph 5 of IT-143R3, explains that goodwill has often been defined by the Courts as the whole advantage of the reputation and connection of the firm which may have been built up by years of honest work or gained by lavish expenditures of money or the privilege, granted by the seller of a business to the purchaser. ...

We were asked to confirm that, in the hypothetical scenario outlined below, (i) paragraph 7(3)(b) (footnote 1) would not apply to prohibit the deduction of certain amounts paid by a Canadian-resident corporation (“CanCo”) in connection with an equity award plan (the “Plan”) and (ii) the amounts would not be subject to Part XIII tax. ...

In this connection, at page 5420 Justice Heald states:      "The respondent relies on the Privy Council case of Punjab Co-operative Bank Limited v. ...

(T)he Department generally accepts that a principal shareholder-manager is entitled to determine a mix of salary and dividend that he considers appropriate....In general, the Department will not challenge the reasonableness of salaries and bonuses paid to the principal shareholders-managers of a corporation when (a) the general practice of the corporation is to distribute the profits of the company to its shareholder- managers in the form of bonuses or additional salaries; or (b) the company has adopted a policy of declaring bonuses to shareholders to remunerate them for the profits the company has earned that are in fact, attributable to the special know-how, connections, or entrepreneurial skills of the shareholders. ...

This same rationale should be applied when considering the taxable portion of benefits provided in connection with the other named conferences. ...

Diguer CGA Valuations Division (613) 957-8953 Attention: XXXXXXXXXX 2005-011592: XXXXXXXXXX ("A Co" XXXXXXXXXX ("Leaseco") This is in response to your e-mail ("Request") dated February 14, 2005 in which you request our views in regard to the above referenced taxpayers proposed change in the method of reporting of expenses incurred in connection with the acquisition of certain properties for purposes of the Income Tax Act (Canada) (the "Act"). ... A Co and Leaseco incur expenses in connection with the acquisition of the CSAs and Leases, respectively and these expenses are referred to as loan originating costs ("LOCs"). ...