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7 November 1990 Ministerial Letter 903108 F- Deductibility of Costs Incurred in Connection with a Takeover Bid Unedited CRA Tags n/a   November 7, 1990 R.K. ... Harms   (613) 957-2109   903108 SUBJECT:  Deductibility of costs incurred in connection with a takeover bid On November 2, 1990, Mr. ...

31 March 1995 Internal T.I. 9503330- INDIANS-- CONNECTION OF INCOME TO RESERVE Unedited CRA Tags 81(1)(a) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Although the employee's residence would not be a factor which connects the Indian's employment income to the reserve, it is appropriate under the circumstances laid out in Guideline 4 to recognize a connection since the employee is working for the benefit of Indians on reserve. However, if the population served by the organization was not comprised almost entirely of Indians who live on reserve, this latter connection would not exist. ...

30 May 2005 Internal T.I. 2005-0130431I7- Internet Connection Fees Unedited CRA Tags 18(1)(a) 9(1) Principal Issues: Whether a self-employed person who uses a computer for both business and personal use can claim a reasonable portion of internet connection fees as a business expense. ... Sue Sohnle Charles Rafuse Client Services Division 613-957-8967 2005-013043 Internet Connection Fees This is in reply to your email of May 12, 2005, concerning internet connection fees. ... Expenditures for internet connection fees at a home office will likely contain varying degrees of personal and business elements. ...

5 November 2010 External T.I. 2010-0379021E5- solely in connection with and as part of news prog Unedited CRA Tags 212(5)(b) Principal Issues: A Canadian resident corporation operates as a television channel. ... Can we say that those highlights are used "solely in connection with and as part of a news program produced in Canada" and be exempted from withholding under 212(5)(b)? ... As the Sports Highlights can be used in both types of television program categories, the payment cannot be said to be for a right that is to be used "solely in connection with and as part of a news program produced in Canada". ...

29 March 1996 External T.I. 9601725- OETC WHERE DUTIES NOT IN CONNECTION WITH QUAL. ... Reasons FOR POSITION TAKEN: Paragraph 122.3(1)(b) requires that the individual perform "all or substantially all of the duties (90% or greater) of the individual's employment outside Canada in connection with a contract... with respect to " a qualified activity. In the antithetical situation, where the individual performs more than 10% of the duties of the individual's employment outside Canada in connection with a contract with respect to an ineligible activity, the individuals' eligibility for the OETC would be denied. ...

25 August 1989 Income Tax Severed Letter 5-8483- Deferred annuities issued in connection with segregated funds Unedited CRA Tags 146(1)(i.1), 146(1)(g)(iii) Dear Sirs: This is in reply to your letter of August 10, 1989 concerning annuities issued by XXX in connection with its segregated funds. ...

30 August 1990 Ruling 900443 F- Deductibility of Utility Service Connection Cost Unedited CRA Tags 20(1)(ee)   August 30, 1990 Current Amendments and Head Office Regulations Division Rulings Directorate B. ... Fontaine Acting Director 957-2095   900443   EACC9225 Paragraph 20(1)(ee) of the Income Tax Act (the "Act") Further to our recent telephone conversation with Don Joy, we request your comments as to whether a utility service connection cost incurred in the circumstances described below should, in terms of fiscal policy, be deductible even though the payment was made to a person other than the person who supplied the service.  ...

25 August 1989 Ruling 58483 F- Annuities Issued in Connection to Segregated Funds Unedited CRA Tags 146(1) qualified investment 19(1) File No. 5-8483   Maureen Shea-DesRosierss   (613) 957-8953 August 25, 1989 Dear Sirs: This is in reply to your letter of August 10, 1989 concerning annuities issued by 24(10 in connection with its segregated funds. ...

7 September 1990 Income Tax Severed Letter- Review of draft form “Designation of Retiring Allowances as Qualifying Transfers in Connection with a Past Service Event in Respect of a Defined Benefit Provision of a Registered Pension Plan” Unedited CRA Tags none Subject: DRAFT FORM "Designation of Retiring Allowances as Qualifying Transfers in Connection with a Past Service Event in Respect of a Defined Benefit Provision of a Registered Pension Plan" This is in reply to your round trip memorandum of August 24, 1990 concerning the review of the above-noted form. ...

7 August 1990 Income Tax Severed Letter- Whether a utility service connection cost incurred should, in terms of fiscal policy, be deductible even though the payments was made to a person other than the person who supplied the service Unedited CRA Tags 20(1)(ee) Subject: Paragraph 20(1)(ee) of the Income Tax Act (the "Act") Further to our recent telephone conversation with Don Joy, we request your comments as to whether a utility service connection cost incurred in the circumstances described below should, in terms of fiscal policy, be deductible even though the payments was made to a person other than the person who supplied the service. ...