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These requirements are as follows: the taxpayer must be employed in the year in question in connection with the selling of property or the negotiating of contracts for the employer (preamble of s. 8(1)(f)); the taxpayer must be obligated under the contract of employment to pay his or her own expenses (s. 8(1)(f)(i)); the taxpayer must be ordinarily required to carry on the duties of employment away from the employer's place of business(s. 8(1)(f)(ii)); the taxpayer must be remunerated in whole or in part by commissions or other similar amounts fixed by reference to the volume of the sales made or the contracts negotiated (s. 8(1)(f)(iii)); the taxpayer must not be in receipt of an allowance for travel expenses in respect of the year in question which is not included in the taxpayer's income by virtue of s. 6(1)(b)(v); s. 6(1)(b)(v) excludes, from the allowances that are otherwise includible in employment income, reasonable allowances for travel expenses received by an employee from the employer in respect of a period when the employee was employed in connection with the selling of property or negotiating of contracts for the employer (s. 8(1)(f)(iv)); the amounts expended by the taxpayer must not be capital expenditures (except as described in s. 8(1)(j) respecting capital cost allowances for motor vehicles that are used or aircraft that are required for use in the performance of duties of the office or employment, or certain related interest financing costs) (s. 8(1)(f)(v)); the amounts expended are not described in s. 18(1)(l) (respecting expenses for the use or maintenance of a yacht, camp, lodge, or golf course or facility (subject to some exceptions) or membership fees or dues for most clubs) (s. 8(1)(f)(vi)); or the amounts expended qualified as deductions in computing the automobile standby inclusion under. 6(1)(e) (s. 8(1)(f)(vii)). ... The jurisprudential tests developed in connection with applying the general prohibition (in the absence of specific provisions to the contrary) in s. 18(1)(b) against the deduction of capital expenditures in the computation of income from a business or property also apply to the prohibition in s. 8(1)(f)(v) against the deduction of capital expenditures in the computation of income from an office or employment (see 6 above). ...

The Explanatory Notes express this as a requirement "that the parties have an expectation, at the time of the investment, that the closer business connection… will continue for the foreseeable future," and state that "this requirement acts as a check to ensure that the connection to Canada is not temporary or contrived." The Explanatory Notes provide the following example: Example 1 – foreign-controlled Canadian manufacturer If commercial aircraft are manufactured by the CRIC and its non-resident parent company, the closer business connection condition in paragraph 212.3(16)(a) would not likely be met if the CRIC were to purchase a non-resident corporation that is a competing commercial aircraft manufacturer. ... If, however, the CRIC were the only company in the multinational group that manufactures military aircraft, then the closer business connection condition in paragraph 212.3(16)(a) may well be satisfied were the CRIC to purchase a non-resident corporation that was a competing military aircraft manufacturer. ...

., the sugar purchases of a sugar refiner), gains or losses on commodities futures contracts in that commodity in which the corporation engages in connection with that commodity will be realized on income account (Atlantic Sugar). ...

As a result of the Budget Amendments, we reviewed a number of prospectus amendments for investment funds, as well as applications that were filed in connection with fundamental changes being made by investment funds to alter their investment structures. ...