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Centre Internship Award and Professional Development Award Services in connection with these awards are performed in Canada and the income therefrom is considered income from employment performed in Canada. ... Pearson Fellowship Award Income from the performance of services in connection with this award is considered employment income. ... Journalism Award Services in connection with this award are performed outside of Canada. ...

If the capital invested by Canco is initially used by CFA in an active business, the causal connection is lost notwithstanding that the invested capital is later employed in an activity from which CFA derives FAPI. ... In such case, we would clearly consider there to be a direct causal connection between the FAPI and the investment in the shares of CFA by Canco. ... In such case we feel the causal connection between the original investment in CFA and the FAPI has been eroded by the fact that the funds had been invested for several years for the purpose of earning income from active business. ...

Income Tax Convention (the “Convention”) with regard to certain “enhanced policy benefits” that may be received, in connection with a demutualization, in respect of certain life insurance policies held by U.S. residents. ... Under paragraph 139.1(4)(a) of the Draft Legislation, for the purposes of that section, where benefits under an insurance policy are enhanced in connection with a demutualization, the value of the enhancement is deemed to be a benefit received by the policyholder and not by any other person. ... Pursuant to subsection 139.1(8) of the Draft Legislation where, in connection with a demutualization of an insurance corporation, a stakeholder receives a “specified insurance benefit” the stakeholder is deemed to have paid and the corporation is deemed to have received, at the time of the demutualization, a premium in respect of the policy to which the benefit relates equal to the value of the benefit. ...

In this connection you have asked us to consider the following factual situation: 1. ... Where paragraph 245(2)(c) is applicable, paragraphs 69(1)(b) and 69(1)(c) will be applied to the donor and the donee respectively, and in this connection the fair market value will be determined without regard to the existence of a non-arm's length option or buy-sell agreement. ... In view of the many difficulties which can arise in connection with non-arm's length buy-sell agreements, actual transactions would seem to be best dealt with on an advance ruling basis. ...

In this connection, we understand that you have reviewed the case of Baroid of Canada Limited vs. ... You are also of the view that the proper capital cost allowance classification of the processing and other assets that would be acquired in connection with the development and processing of the tailings would be Class 28 of Schedule II to the Income Tax Regulations. ... CLASS 28 We do not agree that the proper capital cost allowance classification of the processing and other assets acquired in this connection would be Class 28. ...

Position: For the purposes of paragraph 3 of Article XXIX A, the interest payment will be treated as derived from Canada by USCo in connection with its active trade or business in the United States in the circumstances described below. ... Response 12 The CRA will treat an interest payment from Canco to USco as being derived by USco in connection with USco's active trade or business in the United States if 1) the payment is in respect of indebtedness that was incurred exclusively for the purpose of earning income from Canco's connected business, or 2) Canco can establish that the interest payment was funded out of the earnings of the connected business. ...

Friedlander August 25, 2014 Dear XXXXXXXXXX: Re: Investment Counselling Fees for RDSP Property We are responding to your email of April 4, 2014, concerning certain investment counselling fees paid in connection with a registered disability savings plan (an "RDSP"). You are asking about a deduction under paragraph 20(1)(bb) of the Income Tax Act (the "Act") for investment counselling fees that are paid in connection with investments in a RDSP. ...

Reasons: The draft legislation requires that the award be received in connection with an individual's enrolment in an educational program for which the individual may claim the education tax credit. ... The draft legislation indicates that the exemption will only apply if the award is received in connection with an individual's enrolment in an educational program for which the individual may claim the education tax credit. ...

Position: No Reasons: There must be a connection between the actual travel cost and the amount received by the employer to defray those costs. 972880 XXXXXXXXXX J.E. ... " In our opinion, there must be a connection between the actual travelling expenses incurred by the taxpayer or a member of the taxpayer's household and the amounts paid by the taxpayer's employer to defray those costs. ...

In this respect, these terms suggest a connection to horses. Accordingly, it is our view that, in this context, a “stable” means “a building set apart and adapted for keeping horses.” Therefore, the phrase “stable equipment” refers only to equipment which is used in connection with a stable for horses. ...