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Frappier's claim is made under paragraph 8(1)(f) of the Income Tax Act, which reads: In computing a taxpayer's income for a taxation year from an office or employment, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto: (f) — where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for the taxpayer's employer, and (i) under the contract of employment was required to pay the taxpayer's own expenses, (ii) was ordinarily required to carry on the duties of the employment away from the employer's place of business, (iii) was remunerated in whole or part by commissions or other similar amounts fixed by reference to the volume of the sales made or the contracts negotiated, and (iv) was not in receipt of an allowance for travel expenses in respect of the taxation year that was, by virtue of subparagraph 6(1)(b)(v), not included in computing the taxpayer's income, amounts expended by the taxpayer in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts referred to in subparagraph (iii) and received by the taxpayer in the year) to the extent that such amounts were not (v) outlays, losses or replacements of capital or payments on account of capital, except as described in paragraph (j), (vi) outlays or expenses that would, by virtue of paragraph 18(1)(l), not be deductible in computing the taxpayer's income for the year if the employment were a business carried on by the taxpayer, or (vii) amounts the payment of which reduced the amount that would otherwise be included in computing the taxpayer's income for the year because of paragraph 6(1)(e). 4 Although the considerations that underlie the determination that must be made here are the same whether her income is from a business (section 9) or from employment (section 8) it was agreed that the case should proceed on the basis that she was employed by a brokerage firm and that it was therefore unnecessary to consider whether her income was from a business. ...

Under the terms of the licence agreement, the partnership was obligated (i) to commence operation of the hotel not later than thirty days following completion of the buildings; and (ii) to conform to the standards of quality and design for all furniture, furnishings, supplies and equipment used in connection with such business as approved by Orangeroof. ...

The fees comprising the partnership loss were paid for services rendered in connection with steps taken merely to move the project forward, not with the operation of the facility. [14]            Counsel points out that article 3.13 deals with the obligations of partners to contribute "the cash required to finance the operation of the Windsor Multi-Use Facility to the extent that it is not available out of revenues... ...

He said of subsection 116(1) that the section has application to “the directness of the connection to the practice of law in the broader business sense”: supra at 270. ...

  [10]            Justice Boyle found as a fact that the break fee was paid pursuant to an agreement negotiated by Morguard in connection with its potential acquisition of Acanthus, that Morguard pursued the acquisition in accordance with its established business strategy and in the ordinary course of its normal business operations, and that the receipt of the break fee was a normal and expected incident of its business activities. ...

The Appellant did not have any connection to any of the companies identified above and he had simply contacted CIBC Investors Services Inc. to acquire the shares of these companies. ...

A.D)) for a similar conclusion reached in a different context. [10]            Turning to the second appeal (A-268-15), the Crown claims that although the Tax Court judge purported to assess whether Superior Plus’ partial disclosure of privileged information gave rise to unfairness and inconsistency, he in effect determined that there had been no waiver because the additional information sought by the Crown was neither “vital or necessary” to her case. [11]            The underlying issue essentially turns on the link or connection between the legal opinion on which Superior Plus waived the solicitor-client privilege, and the other legal opinions which it received from its legal Counsel and with respect to which the privilege has not been waived. ...

Yours truly,   Signature     Ann Marie Murell Senior Manager Human Resources   ISSUE   [6]   The issue in this appeal is whether the benefit received in connection with the RSUs should be valued when the award was granted or when the award vested.         ...

With respect to costs, it is clear that the provisions of subsection 178(2) of the Act providing for payment by the Minister of “all reasonable and proper costs of the taxpayer” in connection with the appeal are applicable, and it is hereby ordered accordingly. ...

My understanding of the principle in Yates is that the minimum amount of land which the taxpayer is legally obliged to have in connection with his residence at the time of disposition of the property establishes objectively the amount of land associated with the "principal residence". ...