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Technical Interpretation - Internal
13 September 1995 Internal T.I. 9520497 - MOVING EXPENSES
In addition, the taxpayer did not have an employment position at the time of the move although he expected to obtain an employment position in the near future (a few months) in connection with a manufacturing activity that was to be commenced. ... In connection with these comments, it is our view that if the "old residence" is considered to be the rental unit he occupied following the sale of his home until November of 1991, the costs would not be deductible. ... In connection with the comments in the preceding paragraph, we also wish to note that on page 2 of the individual's letter, it is indicated that he incurred costs of $XXXXXXXXXX (Legal fees and Deed transfer) in connection with the acquisition of the lot purchased in November of 1991 as well as costs (Legal fees) of $XXXXXXXXXX incurred in connection with the financing of the construction of the home. ...
Technical Interpretation - Internal
19 October 2004 Internal T.I. 2004-0094971I7 F - Programme de formation admissible
British Columbia, [1944] CTC 105, le juge MacFarlane au nom de la Cour suprême du Canada, a statué comme suit concernant la portée à donner à l'expression " in connection with ": One of the very generally accepted meanings of "connection" is "relation between things one of which is bound up with or involved in another", or again "having to do with". ... R. (2d) 306 a donné à ces termes une interprétation large: The final question is whether it can be said that the premises were provided "in connection with" the employment. The Shorter Oxford Dictionary defines "connection" as... a "relation between things, one of which is bound up with or involved with another". ...
Ruling
2000 Ruling 2000-0044773 - EMPLOYEE/SHAREHOLDER LOANS
Provided the Lender is the employer and the employee is not a "specified employee" as defined in subsection 248(1), by virtue of subsection 15(2.4), the provisions of subsection 15(2) will not apply to an employee who is a shareholder of Canco or any of its affiliates in respect of Loans or Interest Loans received by the employee from the Lender in connection with their investment XXXXXXXXXX. ... By virtue of the provisions of section 80.5, paragraph 20(1)(c) will apply to permit an employee a deduction in a taxation year equal to the amount of the inclusion in income under subsection 80.4(1) for the year in respect of Loans and Interest Loans received in connection with their investment XXXXXXXXXX, to the extent that the borrowed funds continue to be used for the purpose of gaining or producing income. ... Apart from the application of subsection 6(9) as set out in Ruling C, the provisions of section 6 will not apply to include an amount in the income of an employee solely as a result of XXXXXXXXXX, the acquisition by an employee of XXXXXXXXXX or the receipt of the Loans or the Interest Loans by the employee in connection with their investment XXXXXXXXXX. ...
Technical Interpretation - Internal
27 June 2007 Internal T.I. 2006-0167351I7 - CRL - Contingent Liabilities
They import such meanings as "in relation to", "with reference to" or "in connection with". The phrase "in respect of" is probably the widest of any expression intended to convey some connection between two related subject matters." It is our view, that the phrase "in respect of" is at least as broad, if not broader than the phrase "in connection with". ...
Technical Interpretation - External
18 April 2013 External T.I. 2013-0484631E5 - Employee Bursary & Education Tax Credit
18 April 2013 External T.I. 2013-0484631E5- Employee Bursary & Education Tax Credit CRA Tags Regulation 200(2) 6(1)(a) 118.5 118.6 Principal Issues: Change in position taken in Document 2012-043551 Position: ETC is in fact available to an individual taking a course in connection with his or her employment, provided all other requirements for the ETC are met. ... The ETC is in fact available to an individual taking a course in connection with his or her employment, provided all other requirements for the ETC are met. ...
Technical Interpretation - External
14 January 1997 External T.I. 9635185 - CANADIAN NEWSPAPER OR PERIODICAL
Dodd (613) 957-8953 Attention: XXXXXXXXXX January 14, 1997 Dear Sirs: Re: Section 19 of the Income Tax Act We are writing in connection with your letter dated October 22, 1996. ... At the same time, we would note in connection with your concern regarding subsection 19(8) of the Act that the application of this provision is a question of fact on which it may not be possible to predetermine all of the relevant facts. ...
Technical Interpretation - External
30 November 1992 External T.I. 9231335 F - Advantages Out Of An RRSP
In general, as we stated in our previous letter, amounts paid into a plan in connection with the assets of a plan are not considered advantages to the plan's annuitant. Expanding on this, we can also state that expenses incurred by a trustee in the overall maintenance of a plan's assets will generally be considered to be in connection with the plan's assets. ...
Ministerial Letter
3 July 1992 Ministerial Letter 9218428 F - Deductibility Of Mortgage Interest
A building must be used in connection with the earning of business income or property income in order for mortgage interest expenditures to be deductible. If the building is not being used for income-earning purposes, as in the case of a personal residence for example, then expenditures incurred in connection with the property would not be deductible. ...
Ministerial Letter
18 January 1990 Ministerial Letter 58948 F - Technical Interpretation - Set-up Costs - RRP
You further enquire as to whether an employee covered by an individual RPP could deduct any expenses paid by him in connection with establishing the RPP. ... In our opinion, an employee is not entitled to deduct expenses paid in connection with establishing an individual RPP since these expenses belong to the employer or the trustee of the RPP. ...
Miscellaneous severed letter
8 July 1981 Income Tax Severed Letter RCT 3-6201 F
8 July 1981 Income Tax Severed Letter RCT 3-6201 F Unedited CRA Tags 85 Section 85Elections As discussed with you recently, enclosed herewith are the memorandum and related documentation received from the Saskatoon District Office in connection with the above-noted taxpayer. ... We await your comments in this matter and shall be pleased to provide any further assistance you may require in this connection. ...