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Definition of advantage 3.5 An advantage in relation to a registered plan is defined in subsection 207.01(1) as any of the following: certain benefits or debt that are conditional on the existence of the plan, subject to listed exceptions (see ¶3.6 to 3.15) an increase in the FMV of the property held in connection with the plan which increase is reasonably attributable to certain transactions or amounts (see ¶ 3.16 to 3.26) income or a capital gain that is reasonably attributable to certain property or transactions in respect of the plan (see ¶ 3.28 to 3.31) a registered plan strip in respect of the plan (see ¶ 3.32 to 3.34) Conditional on plan 3.6 Paragraph (a) of the definition of advantage includes any benefit, loan or indebtedness that is conditional in any way on the existence of the registered plan, subject to certain enumerated exceptions discussed in ¶3.7 to 3.12. ... That is, the advantage tax will nonetheless apply in respect of any future increases in the total FMV of the property held in connection with the plan that are reasonably attributable, directly or indirectly, to the swap transaction. ... Settlement payments 3.42.1 Occasionally, payments may be made to settle a class-action lawsuit or other legal proceeding in respect of actionable losses incurred in connection with assets of registered plans. ...

Amounts excluded from gross revenue 2.23 Subsection 402(5) of the Regulations provides that for purposes of subsection 402(3), gross revenue of a corporation does not include interest on bonds, debentures or mortgages, dividends on shares of capital stock, or rentals or royalties from property that is not used in connection with the principal business operations. 2.24 In Provincial Income Allocation Newsletter No. 1 the CRA confirmed that a broad interpretation of the excluded amounts is appropriate for the purposes of Part IV of the Regulations. Under such a broad interpretation, interest on promissory and other notes, bankers’ acceptances, intercompany loans, certificates, guaranteed investment certificates, and any unsecured debt instruments or other similar obligations would also be excluded from the gross revenue of a corporation. 2.25 In addition, the reference in subsection 402(5) to “that is not used in connection with the principal business operations of the corporation” refers only to “rentals or royalties from property” and not to the other items enumerated in that subsection. 2.26 Examples of amounts that would normally be excluded in determining gross revenue of a corporation for purposes of Part IV of the Regulations include the following: Amounts received or receivable in respect of expenditures incurred by the corporation. ... Other factors that are relevant in determining whether an individual is an employee of a permanent establishment of any particular province include the following: whether the individual is also considered to be an employee of that establishment for provincial government related filing requirements (for example, income tax deduction, medical premium deduction, etc.); whether the employee maintains an office or other connections in that establishment; and whether the employee normally reports to or receives instructions from that establishment. 2.61 Under paragraph 413(1)(a) of the Regulations, where a corporation is not resident in Canada, “salaries and wages paid in a year” does not include salaries and wages paid to employees of a permanent establishment outside Canada. ...

X lived in the residence from October 15, 2007 until he disposed of the property on December 1, 2011 for $250,000, incurring no costs in connection with the disposition. ... Form T2062, Request by a Non-Resident of Canada for a Certificate of Compliance Related to the Disposition of Taxable Canadian Property, or a similar notification, must be filed in connection with a request for a section 116 certificate. ... It has been assumed in these examples that, on each actual disposition, no costs were incurred in connection with that disposition. ...

Where the taxpayer has a perceptual disability, the cost of talking textbooks used by the taxpayer in connection with the taxpayer's enrolment at a secondary school in Canada or at a designated educational institution is an eligible expense, provided that a medical practitioner has certified in writing, that the taxpayer is a person who, because of that disability, requires those textbooks. ... This requirement remains if the attendant is resident in Canada for tax purposes. 3.10 Therefore, if a taxpayer who is resident in Canada for tax purposes has a perceptual disability and incurs the cost of a talking textbook used in connection with the taxpayer’s enrolment at a secondary school located outside of Canada or, if the taxpayer is a person with a disability who incurs the cost of attendant care provided outside Canada, the costs incurred will be eligible for the disability supports deduction assuming all the other requirements of section 64 (as discussed in ¶ 3.1 to 3.8) are met. ...

In this context, the words in respect of have been held by the courts to imply a connection between the loss of employment and the subsequent receipt, where the primary purpose of the payment is to compensate for the loss of employment. Two questions set out by the courts to determine whether such a connection exists for purposes of a retiring allowance are as follows: Question 1 – But for the loss of employment would the amount have been received? ...

Personal or living expenses 2.34 Expenses relating to an individual’s home that are personal or living expenses are specifically precluded from deduction by paragraph 18(1)(h). 2.35 The term personal or living expenses is defined in subsection 248(1) to include: “… the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or common-law partnership or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit.” 2.36 Generally, an expense is incurred in connection with a business if there is a business purpose or need for the expenditure. ...

For more information, see Lottery Prize Commissions. 1.17 Paragraph 40(2)(f) specifies that no taxable capital gain or allowable capital loss results from the disposition of a chance to win or a right to receive an amount as a prize in connection with a lottery scheme. ... Pool system betting 1.19 Paragraph 40(2)(f) also provides that no taxable capital gains or allowable capital losses arise from the disposition of a chance to win a bet or a right to receive an amount as winnings on a bet in connection with a pool system of betting. ...

Whether these are part of the same business depends upon the connection, interlacing, dependence, and unity, of the operations. ...

Accordingly, such an artist or writer is entitled to deduct reasonable expenses incurred in connection with earning income from that business, except to the extent that they are denied, or limited, by a provision of the Income Tax Act. ... He enjoys mixing with other artists, talking to people, and making connections. ... An artist would generally be considered to have made a gift of capital property when the property gifted is property that would not normally be produced and sold in connection with their business. ...