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Linden J.A. noted (at p. 5608) that the phrases "because of" or "as a consequence of" in s. 80.4(1) required "a strong causal connection" and went on to find that because the employees (who already had Calgary homes) obtained their new form of mortgage financing largely independently of employer involvement, it was reasonable to consider that the new mortgage debt was incurred "in order to obtain ownership of a house, not... 'as a consequence of'... employment". ...

., 89 DTC 5404, [1989] 2 CTC 246 (FCA)-- summary under Personality Summary Under Tax Topics- General Concepts- Personality The taxpayer ("MerBan") in connection with a leveraged share acquisition arranged for borrowings to be made to two special purpose subsidiaries in order to limit its liability and to facilitate the use of an income debenture. ...

., 89 DTC 5404, [1989] 2 CTC 246 (FCA)-- summary under Separate Existence Summary Under Tax Topics- General Concepts- Separate Existence The taxpayer ("MerBan") in connection with a leveraged share acquisition arranged for borrowings to be made to two special purpose subsidiaries in order to limit its liability and to facilitate the use of an income debenture. ...

MNR, 60 DTC 1018, [1960] CTC 1 (Ex Ct)-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 9- Timing The taxpayer, which followed the "completed contract" method of recognizing income on long-term contracts for the excavation of sewers and water systems for accounting purposes, was permitted to deduct all the costs incurred by it in connection with those contracts only in the years those costs were made or incurred. ...

Flanigan held that the accounting, legal and investment advisory fees incurred in connection with this reorganization all were deductible under s. 11(1)(cb)(i) and noted that it was not necessary for the issuance of the shares to have resulted in the raising of fresh capital. ...

The Queen, 94 DTC 1964, [1994] 2 CTC 2439 (TCC)-- summary under Section 68 Summary Under Tax Topics- Income Tax Act- Section 68 All the proceeds received by the taxpayer in connection with the sale of his land to TransCanada Pipelines Limited ("TCP") were to be characterized in that manner notwithstanding that prior to reaching an agreement for the sale, the taxpayer had sought TCP's agreement to instead pay him business interruption compensation in respect of TCP's plan to run gas pipelines under the surface of his property (rather than purchasing his land). ...

Whaling, Re, 99 DTC 5478, [1999] 4 CTC 221 (Ont CA)-- summary under Paragraph 146(2)(c.3) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(2)- Paragraph 146(2)(c.3) In connection with a loan to the taxpayer by the CIBC, which was the depositary for two RRSPs that he opened up with the CIBC, it was agreed that if he should fail to meet the repayment term for loans the bank made to him he would, at the bank's request, collapse the RRSPs in order to repay the loans, or if the RRSPs could not be collapsed, the funds in the RRSPs would be applied against the loans at maturity. ...

He used a room in his apartment for preparing weekly invoices (which he sent to his placement agency), updating his resumé, typing letters to prospective employers, and making calculations and preparing sketches in connection with the current engagement. ...

Profit- Real Estate The taxpayer was entitled to a fee for services rendered to the owner of a property in connection with the finding of a purchaser of a part interest in the property. ...

Accordingly, the $1.25 million was not incurred in connection with or incidental to or arising from a borrowing. ...