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After finding that s. 95(2)(b)(i) did not apply to include the fees of the US Affiliates in computing the foreign accrual property income (FAPI) given the reciprocal nature of the services, Bocock J found, in the alternative, in light of the broad meaning of “in connection with” and the important and ongoing role which the R&D services played in meeting the immediate demands of smartphone customers (e.g., teleco carrier testing and bug fixes), that the exclusion in s. 95(3)(d) applied. Words and Phrases in connection with ...

The term that is used to indicate a connection between the relevant amount of income, whatever that may be, and each of the United States tax and the Australian tax is 'in respect of'. ... No doubt, in each case the connection cannot be a distant, arbitrary or illogical one. But to the extent that it is necessary to identify the connection more precisely, that must be done in accordance with the provisions of the law of Australia. ...

In its relevant VAT return, BLP deducted the VAT paid on three invoices for professional services supplied to it by merchant bankers, solicitors and accountants respectively, in connection with the share sale. ... Under those circumstances the input tax charged on the advisory services supplied in connection with taking up the loan may be deducted, if it is attributable to taxable transactions. ...

Attorney General of Canada, 2018 QCCS 3381, aff'd 2020 QCCA 697-- summary under Negligence, Fiduciary Duty and Fault Summary Under Tax Topics- General Concepts- Negligence, Fiduciary Duty and Fault damages awarded against CRA for inter alia making unreasonable reassessments CRA made unreasonable reassessments with the knowledge that they were contrary to advice received from Rulings, offered in a settlement offer to settle elements that it knew it was going to abandon, failed to honour a commitment to give notice of the reassessments and delayed disclosures under the Access to Information Act process and made an inquiry with the Bermuda authorities that falsely stated that it was made in connection with a "criminal" investigation. In light of these and other failings by CRA, Hamilton JCS awarded the taxpayers approximately $4.8 million in damages comprised principally of interest that the large corporations were required to pay (i.e., 50% of the amounts) on the reassessments before they were reversed, a portion of the professional fees that were incurred in connection with the audit and, in the case of two of the individual taxpayers, $250,000 for damage to reputation (having regard to the false "criminal investigation" statement) and for stress, trouble and inconvenience. ...

After stating (in applying Hauser) that “the question of a person’s residency in one jurisdiction will be answered by examining the person’s connection to that jurisdiction and will not be influenced by evidence of links to a second jurisdiction” (para. 108) and finding that Mr. ... Sampson spent close to half of his time in British Columbia points to a clear personal connection with the province. ...

Canada, 2001 DTC 5471, 2001 FCA 260-- summary under Subsection 248(10) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(10) s. 248(10) assimilates a subsequent transaction to a common-law series if it has some connection with the series and is completed in contemplation thereof Rothstein JA found that transactions that had the effect of transferring properties with accrued losses to a partnership were a “common law” series, which he defined (at para. 24) as follows: [F]or there to be a series of transactions, each transaction in the series must be pre-ordained to produce a final result. ... As long as the transaction has some connection with the common law series, it will, if it was completed in contemplation of the common law series, be included in the series by reason of the deeming effect of subsection 248(10). ...

In 2007, FHI was approached on an urgent basis by Legacy to unwind the above "reciprocal loan arrangement" in connection with an imminent sale of the Washington hotel. ... Essentially the same reciprocal loan structure and mistaken unwinding strategy was used in connection with a Seattle hotel of Legacy. ...

The Queen, 2005 TCC 92-- summary under Subsection 141.01(2) Summary Under Tax Topics- Excise Tax Act- Section 141.01- Subsection 141.01(2) allocation between costs incurred by trustee in bankruptcy for bankrupt financial institution to provide litigation services to creditors, and costs incurred in connection with its action qua trustee The trustee in bankruptcy ("Richter") for Castor Holdings Ltd. ... In addition to suing- in its capacity of trustee in bankruptcy for the Castor estate (the "Estate")- the former Castor auditors ("C&L") for $40 million in damages sounding in contract, Richter began a "litigation support business" of providing assistance to the creditors (including hiring professionals and experts) in connection with their action sounding in negligence against C&L for $800 million in damages. ...

In 2007, FHI was approached on an urgent basis by Legacy to unwind the above "reciprocal loan arrangement" in connection with an imminent sale of the Washington hotel. ... Essentially the same reciprocal loan structure and mistaken unwinding strategy was used in connection with a Seattle hotel of Legacy, and addressed by Newbould J in the same manner. ...