Search - connection

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. ...

11 October 1978 Income Tax Severed Letter Attention XXXX October 11, 1978 Dear Sirs: Re: Mortgage Investment Corporations This is in reply to your letter of September 26, 1978 in connection with funds borrowed to finance the operations of a mortgage investment corporation. ... Initially, we should state that Interpretation Bulletin IT-239R is specifically directed towards the deductibility of capital losses, and the comments in paragraph 8 thereof in connection with the deductibility of interest are not a statement of general policy but are intended to apply solely to accomodate those situations involving a shareholder and his closely held corporation, where the reason for the borrowing and relending is to enable the corporation to overcome financial difficulties. ...

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. ...

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 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. ...

Principal Issues: 1.whether proposed Deposit B mine will be extension of Deposit A mine or a new mine for CEE definition in 66.1(6)(f) and (g) 2.whether Deposit B mine will be new mine or part of a mine that has come into production in reasonable quantities for CCA 3.whether successored Deposit A mine expenses available to reduce income from Deposit B mine; that is, whether same Canadian resource property involved for Deposit A and Deposit B for 66.7(3) and (4) successor rules Position: 1.no- new mine for CEE; not relevant whether one mineral resource or two 2.new mine for CCA 3.yes- same lease, same Canadian resource property, not relevant whether one mineral resource or two Reasons: 1.no common underground workings or connections between the two mines, Oro Del Norte, Bethlehem Copper, Falconbridge Copper, Sept. 1985 Dept. of Finance Technical Notes re 66.1(6)(a)(iii.1) 2.no common underground workings or connections between the two mines 3.66(15) and 248(1) definition "Canadian resource property"; the "particular property" is the lease, and the lease which applies to the new mine is the same lease that was received from the original owner XXXXXXXXXX 970647 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 1997 Dear Sirs: Re: XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX requesting an advance income tax ruling on behalf of the above-referenced taxpayer in connection with the proposed transactions described below. ... Converted from previously existing mineral claims XXXXXXXXXX, the lease has a primary term of XXXXXXXXXX years. 7.No exploration or mining activity will be conducted at Deposit A during the period that Deposit B is being developed or mined. 8.None of the work on the Deposit B mine will be conducted from the Deposit A mine, nor will there be any underground connections between the two mines. 9.No underground facilities, workings or equipment from the Deposit A mine (which is currently closed with no plans for any resumption of activity) will be used for development and mining at the Deposit B mine and there will be no connections between such facilities, workings or equipment. ... Other Information 14.To the best of your knowledge and that of Resource Co., none of the issues involved in this ruling is being considered by a Tax Services Office or Taxation Centre in connection with a tax return already filed by Resource Co. or a related person, none of the issues involved is the subject of any Notice of Objection or is under appeal, and none of the issues involved is the subject of a ruling previously issued by the Directorate. ...

Except in connection with such agreement, Pubco and Subco have discontinued all of their prior activity in the XXXXXXXXXX Business following its sale. ... Distribution #1 and Distribution #2 are both intended to represent a special transaction in connection with the Reorganization. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

The individual cannot have been employed or engaged by the employer in the same year, otherwise than as a volunteer, in connection with the performance of any of the duties described, or similar duties. Based on the information provided, it is our view that the individual does not qualify for the exemption under subsection 81(4) of the Act because the individual performs firefighter duties in connection with his employment with the municipality. ...

The provision reads in part "the benefits of this [Treaty] shall apply to that resident person [US Parent] with respect to income derived from [Canada] in connection with or incidental to that trade or business (including any such income derived directly by that resident person through one or more other persons that are residents of [Canada]…" Would the CRA consider the gain to be derived from Canada where Canada taxes the gain under domestic law? ... In particular, paragraph 3 provides that treaty benefits may be available to a US resident with respect to income derived from Canada, provided that the income is derived in connection with, or is incidental to, the active conduct of a trade or business (other than certain investment businesses) carried on in the US by the US resident, or a person related to the US resident, and provided that the US trade or business is substantial in relation to the activity carried on in Canada giving rise to the income. ...

A pellet insert requires an electrical connection [hard wiring] with most inserts requiring a conventional flue. ... Most pellet inserts require an electrical connection (hard-wired), as well as a conventional flue. ...

In connection with the Plan, the Employer has established a trust (the “LOC Trust”) such that the assets held in the LOC Trust are separate from the assets of the Employer. ... In our view, an amount is not paid as a distribution under the RCA unless the amount is paid from property held in connection with the RCA. ...