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18 November 2014 TEI Roundtable

In connection with those risk assessments, the CRA held more than 175 face-to-face meetings with officials from large businesses. ...

5 October 2018 APFF Roundtable

Preliminary CRA written response to Q.8(a) Paragraph 8(1)(f) provides that a taxpayer who was employed in the year in connection with the selling of property or negotiating of contracts for the taxpayer’s employer, may deduct in computing the taxpayer’s income amounts expended by the taxpayer in the year for the purpose of earning income from the employment subject to certain conditions provided for in that paragraph. ...

21 May 2014 CBA Roundtable

As indicated in B-103, to be considered a service in relation to a location-specific event for purposes of section 28 of the Regulations, there must be a direct connection between the service and the event. ...

7 June 2019 STEP Roundtable - Official response

The T3 return serves to report information about the trust itself along with information that affects the taxation of persons who have some connection to the trust. ...

28 February 2019 CBA Roundtable

Q.16 ONEnergy and s. 141.1(3) ONEnergy (2018 FCA 54) held that s. 141.1(3), which provides for an input tax credit where the property or service is acquired in connection with the acquisition, establishment, disposition or termination of a commercial activity, is more specific than s. 141.01(2), so that a person will not lose the entitlement to claim an ITC solely because that person is not making any taxable supplies at the time that such property or service is acquired. ...

Subsection 212.3(9) - Commentary

., an investment described in paragraph 212.3(10)(b)), dividends or reductions of PUC in respect of the class or series of shares of the subject corporation (or the portion of a reduction of PUC or a dividend in respect of substituted shares that "can reasonably be considered to relate to the subject shares"), or repayments of or proceeds from the disposition of debt obligations, or other amounts owing by the subject corporation, in connection with an investment described in ss. 212.3(10)(c), (d) or (e)(i). ... In connection with a public offering by a listed non-resident company (FA), CRIC subscribes $100 for 100 units of FA, with each unit consisting of one common share and a warrant to acquire a further common share at a subscription price of $1 – with CRIC thereby acquiring 15% of the common shares of FA. $80 of this amount is reasonably allocated to the common shares, and $20 to the warrants. ...

Subsection 212.3(7) - Commentary

There is an exclusion for contributed surplus which arose "in connection with" an investment to which s. 212.3(2) applied. ...

S1-F2-C3 - Scholarships, Research Grants and Other Education Assistance

In both cases, the deduction applies only to tuition assistance and not to other types of assistance a student may receive in connection with the student’s training. ... The deduction can also apply to tuition assistance received in connection with basic adult education. ... An award will be considered to be received in connection with the taxpayer’s enrolment in an educational program where it satisfies the conditions outlined in paragraph 56(3.1)(a) (see ¶ 3.96). ...

G E Financial Investments v.The Commissioners for Her Majesty's Revenue & Customs, [2021] UKFTT 0210 (Tax Chamber), ultimately aff'd [2024] EWCA Civ 797 -- summary under Article 4

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. ...

Ritchie v. The Queen, 2018 TCC 113 -- summary under Subpargraph 12(1)(x)(viii)

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

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