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Wheeler, "The Connection of Income to a Reserve" (Paper presented to the Insight Aboriginal Conference, March 31, 1995) (C.T.O. "Indians- Connection of Income to a Reserve").-- summary under Section 87 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Indian Act- Section 87 ...

Requirement for direct connection between instruction and school credit, or curriculum-designed, course 9. ... In order for the exemption to apply, it must be evident that there is some direct connection between the supply of the service of tutoring or instructing in question and the course approved for credit by, or the curriculum designated by, a school authority. ...

June 2012 Draft GST/HST Technical Information Bulletin B-103, "Harmonized Sales Tax- place of supply rules for determining whether a supply is made in a province"-- summary under Subsection 13(1) Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 13- Subsection 13(1) Includes: Example 92 (the BC office of a corporation which receives the advice and had meetings with the advisor has a closer connection than the head office in Ontario which contracted with the advisor and the Alberta accounting office to which the invoice was directed to be sent); Example 95 (head office with which the consultant entered into a "global framework" agreement does not have as close a connection as the regional office determining the specific service which it requires and issues a purchase order); and Example 96 (the business address of a mutual fund trust in Ontario has a closer connection the the services of an accounting firm than the address of the fund sponsor or of the trustee). ...

An address of the recipient obtained by a supplier is only relevant [as a business address] if it is obtained in the ordinary course of the supplier's business practices in connection with the supply. ... An address of the recipient obtained by a supplier in the ordinary course of business could therefore include any of the following: an address of the recipient from which the supplier is hired in connection with a supply pursuant to an agreement for the supply (the contracting address) an address of the recipient that the supplier deals with in connection with a supply a billing address of the recipient in connection with a supply Example 8 A student in Ontario with a New Brunswick permanent address purchases for $250 at an Ontario membership desk a six-month membership to use the club’s fitness facilities, which are in both provinces. ...

Any amount payable under the provincial climate change legislation that is described as a fine or penalty as a consequence of the non-compliance will be precluded from deduction by section 67.6. 1.20 If a fine or penalty is incurred in connection with the acquisition of an asset for which capital cost allowance (CCA) may be claimed, the fine or penalty may be included in the capital cost of that asset (or the CCA class to which the asset belongs). If a fine or penalty is incurred in connection with the acquisition or production of inventory, the fine or penalty is included in the cost of inventory. 1.21 If a fine or penalty is incurred in connection with the acquisition of an eligible capital property, the fine or penalty is an eligible capital expenditure provided all the other tests in the subsection 14(5) definition of eligible capital expenditure are met. 1.27 Section 67.6 prohibits the deduction of a fine or penalty imposed under a foreign statute.... 1.29 Fines or penalties levied as a result of a criminal conviction may be precluded from deduction by section 67.6…. ...

October 1989 Revenue Canada Round Table- Q.26 (Jan. 90 Access Letter, ¶1075)-- summary under Subsection 402(5) Summary Under Tax Topics- Income Tax Regulations- Regulation 402- Subsection 402(5) The words "used in connection with the principal business operations of the corporation" relate solely to the words "rentals or royalties from property". Therefore, if a corporation is formed for the sole purpose of holding long-term investments, thereby receiving dividends and interests, it receives those returns on property that is used in connection with this principal business. ...

26 February 2015 CBA Roundtable, Q. 17-- summary under Subsection 186(1) Summary Under Tax Topics- Excise Tax Act- Section 186- Subsection 186(1) costs incurred respecting capital raises to fund an operating subsidiary are not creditable Memorandum 8.6, para. 11, Example 3, indicates that “HoldCo” may not claim input tax credits (ITCs) under s. 186(1) for legal and accounting costs incurred in connection with raising money through issuing shares, even where the issuance proceeds are used to purchase additional shares in “OpCo,” all of whose property is acquired for consumption, use or supply in widget manufacturing- on the basis that the services are acquired for consumption or use in relation to the first order supply (the share issuance) and not in relation to the shares of OpCo. However, in Stantec the Tax Court found that the s. 186(1) language implied a wide, rather than narrow, connection between the property and services acquired and the shares of the Opco, and rejected the above-noted example (published at that time in P-196R), stating: I see no support for this one step removed doctrine. ... In light of the Tax Court’s explicit rejection of the “one step removed doctrine,” does CRA intend to revise Example 3 to permit a Holdco to claim ITCs for costs incurred in connection with a share issuance of its own shares that relates directly to a purchase of additional shares in an Opco? ...

The active business carried on by USco in the United States is substantial in relation to the active business carried on by Canco. 1) Canco distributes a portion of its after-tax income from its active business to USco in the form of dividends on its shares Since USco and Canco carry on parallel business activities and the dividends are paid out of the after-tax earnings from Canco's business, we would consider the dividends received by USco to be derived in connection with USco's active business. 2) USco sells the shares of Canco and realizes a taxable capital gain Since the value of the Canco shares (and thus the taxable capital gain) is derived from an active business in Canada that is parallel to the active business carried on by USco in the United States, we would consider the taxable capital gain on the disposition of the shares of Canco to be derived in connection with USco's active business. ...

In finding that s. 175 would generally not so apply, CRA stated: For purposes of section 175, in order for the consumption or use of the property or service by the employee to be considered to relate to the activities of the employer, there must be a direct connection between the consumption or use of the property or service and the activities engaged in by the employer. [S]ince a medical or dental service is acquired by an employee in relation to his or her personal health and well-being, there would not be a direct connection between the service and the activities of the employer. ...

Under the terms of the Nominee Agreement, it agreed to deal with the Property only on the directions of the Owner and to execute and deliver all agreements, leases, covenants, instruments and assurances required by Owner from time to time in connection with the Property. In connection with the Owner’s development of the Property, the Nominee has contracted on behalf of the Owner for the supply of goods and services from third parties, with the resulting contracts and invoices being in the name of the Nominee. ...