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Such trips are considered to be employment-related rather than personal driving, and any reasonable allowance paid in connection with such milage is consider to be non-taxable pursuant to subparagraph 6(1)(b)(vii.1). ... Any allowance paid in connection with such travel is taxable pursuant to paragraph 6(1)(b) and would be considered as "other remuneration" for purposes of subsection 81(3). ...

Will expenses in connection with costs of leasing a personal computer ("PC") to earn commission income be deductible? ... Alternatively, will capital cost allowance ("CCA") in connection with the acquisition of a PC to earn commission income be deductible? ...

Subparagraph 3(d) of Article XI the Convention provides that interest arising in a Contracting State shall be exempt from tax in that State if: "the interest is beneficially owned by a seller who is a resident of the other Contracting State and is paid by a purchaser in connection with the sale on credit of any equipment, merchandise or services, except where the sale is made between persons dealing with each other not at arm's length;" You have asked for our views as to whether the word "seller" in the above mentioned provision can be interpreted to include the assignees of the seller who hold the purchase money paper created in connection with "a sale on credit of equipment, merchandise or services" made at arm's length if: a) the assignment is contemporaneous with or subsequent to such a sale, or b) the assignment is made with or without recourse to the "seller" assignor by the assignee. ...

New paragraph 85(1)(c.2) of the Act as enacted by Bill C-18 applies where a taxpayer carrying on a farming business, the income from which is computed in accordance with the cash method, transfers to the corporation property, which was inventory owned in connection with that farming business immediately before the transfer of the property to the corporation. ... Pursuant to new subparagraph 85(1)(c.2), a growing crop of plants acquired on a subsection 85(1) rollover by a corporation in connection with a cash method farming business would be purchased inventory of the corporation for purposes of paragraph 28(1)(c) of the Act. ...

23 March 1982 Income Tax Severed Letter RRRR59- Whether entity is corporation or partnership for foreign affilate rule purposes Unedited CRA Tags 24(1) This is further to your memoranda of February 16, March 4 and March 9, 1982 in connection with whether the above entities are either corporations for purposes of the foreign affiliate rules or partnerships, as claimed. Limitada: In connection with the "limitada" we offer the following comments which generally support your contention that it is a "corporation". (1) Paragraph 3 of IT-343R dated September 26, 1977 refers to this type of entity which is found in most of the Latin American countries. ...

It is our view that where the Canadian cable TV companies pick up distant signals which are transmitted from films or video tape, any payments made in respect of the retransmissions of such signals will fall within the wording of paragraph 212(5)(b) of the Act as payments for the use of "a film, video tape or other means reproduction for use in connection with television". In the case where live broadcasting of a sporting or other events are retransmitted, we are of the view that such payments will fall within the words "or other means of reproduction for use in connection with television" used in paragraph 212(5)(b) of the Act. ...

It should be noted that Canada has no authority in connection with the administration and enforcement of the United States estate tax and that our opinion in connection therewith would not be binding on the United States. ...

8 September 1992 Income Tax Severed Letter 9203675- Foreign Affiliate- Services Rendered to Shareholder Unedited CRA Tags 95(2)(b), 95(3)(b) 920367 Olli Laurikainen (613)957-2116 24(1) Attention: 19(1) September 8, 1992 Dear Sirs: Re: Paragraph 95(2)(b) and 95(3)(b) of the Income Tax Act (the "Act") This is in reply to your letter dated January 31, 1992 wherein you inquired about the meaning of the phrase "services performed in connection with the purchase or sale of goods" in paragraph 95(3)(b) of the Act. ... In our view those duties would generally be considered services that are performed in connection with the purchase of goods. ...

In our opinion a finders fee paid to a non-resident for services rendered in connection with a sale of property would generally be subject to the withholding of Part XIII tax pursuant to clause 212(1)(d)(iii)(C) of the Act where the finder's fee is based on profits from the sale. Furthermore, we are of the view that the phrase "but not including a payment for services performed in connection with the sale of property or the negotiation of a contract" in subparagraph 212(1)(d)(iii) would not exempt such a finder's fee from Part XIII tax unless the non-resident is directly involved in the sales activity (e.g. where the non-resident sells property of the Canadian payor and receives a commission therefore). ...

In our opinion a finders fee paid to non-resident for services rendered in connection with a sale of property would generally be subject to the withholding of Part XIII tax pursuant to clause 212(1)(d)(iii)(C) of the Act where the finder's fee is based on profits from the sale.  Furthermore, we are of the view that the phrase "but not including a payment for services performed in connection with the sale of property or the negotiation of a contract" in subparagraph 212(1)(d)(iii) would not exempt such a finder's fee from Part XIII tax unless the non-resident is directly involved in the sales activity (e.g. where the non-resident is sells property of the Canadian payer and receives a commission therefore).  ...