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After quoting inter alia (at para. 45) from Marcel Widrig that the quoted wording requires “effective personal attachment to a territory,” Brooks J stated (at para. 62): [T]he construction of Article 4 advanced by HMRC requires both worldwide taxation and a connection or attachment to the contracting state concerned. In my judgment, this is the correct approach as it takes into account the common feature or similarity of domicile, residence, citizenship etc, in the context of the Convention, ie that they are all criteria providing, in addition to the imposition of a worldwide liability to tax, a “ connection ” or “ attachment ” of a person to the contracting state concerned. ... [emphasis in original] Brooks J went on to finding that the mere stapling of the GEFI stock did not give rise to the required connection. ...

It was paid in connection with the Appellant’s granting of the easement on his property. ...

In finding that the HST incurred by Look on its related litigation costs qualified for input tax credits by virtue of being incurred in connection with the termination of its commercial activity so as to engage s. 141.1(3), Webb J.A. stated (at paras 17, 18 and 34): …[T]he litigation should be characterized as a claim for overpaid remuneration. ... Therefore, there is a connection between the termination of Look’s commercial activity and the legal services acquired in relation to the litigation against the Former Executives that would be sufficient to permit Look to claim the input tax credits …. ... However, if the registrant is acquiring a property or a service in connection with the acquisition, establishment, disposition or termination of a commercial activity, that person will not lose the entitlement to claim an input tax credit solely because that person is not making any taxable supplies at the time that such property or service is acquired. ...

Canada, [2000] GSTC 109 (FCA)-- summary under Subsection 169(1) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(1) cloth acquired to be made into farming work clothes was acquired in connection with the farming commercial activity In finding that heavy cloth purchased by a Hutterian colony (which was engaged in a farming business) to be made into work clothes for its members was eligible for the ITCs claimed by the colony for 50% of the GST payable on the purchases, Malone J.A. indicated (at para. 25): Once an item is found to be acquired and used in connection with the commercial activities of a GST registrant and that item directly or indirectly contributes to the production of articles or the provision of services that are taxable, then an ITC is available using the formula in that subsection. In a dissenting opinion, Evans J.A. agreed with the majority that "for the goods to be acquired for use 'in the course of commercial activities', there must be a functional connection between the needs of the business and the goods" (para. 31), but disagreed as to whether the connection was sufficient on the present facts. ...