Search - connection

In general terms, the deduction offsets the income inclusion in respect of benefits provided by an employer to an employee or the employee's family with respect to trips made for the purpose of obtaining necessary medical services not available locally or with respect to travelling expenses in connection with not more than two other trips per year. ... " as required by paragraph 110.7(1)(a) of the Act, there must be a connection between the actual travel expenses incurred by a taxpayer or a member of a taxpayer's household and the amounts paid by the taxpayer's employer to defray those costs. ...

The reference in subsection 402(5) of the Regulations to "that is not used in connection with the principal business operations of the corporation" refers only to "rentals or royalties from property" and not to the other items enumerated therein. ...

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. ...

The monthly allowance is deemed to be in excess of a reasonable amount for two reasons: first, the allowance is not based solely on the number of kilometres for which the motor vehicle is used in connection with or in the course of his office or employment (subparagraph 6(1)(b)(x) of the Act) and secondly, because the clergyman is receiving both an allowance in respect of the business use of the motor vehicle and is reimbursed for expenses in respect of the same business use (subparagraph 6(1)(b)(xi) of the Act). ... The preamble to subparagraphs 6(1)(b)(x) and (xi) or the Act states that "for the purposes of subparagraphs (v), (vi) and (vii.1), an allowance received in the year by the taxpayer for use of a motor vehicle in connection with or in the course of his office or employment shall be deemed to be in excess of a reasonable amount... ...

All contributions made under the EBP after the establishment of the Statutory Arrangement and all property that can reasonably be considered to derive from those contributions are deemed to be property held in connection with the Statutory Arrangement and not in connection with the existing arrangement. ...

Short   (613) 957-2134 November 6, 1989 Dear Sirs: Re:  Automobile Allowances This is in reply to your letter dated July 14, 1989, wherein you have requested an interpretation of subparagraph 6(1)(b)(v) and paragraph 18(1)(r) of the Income Tax Act (the "Act") in connection with the following situation: A commission based employee receives an automobile allowance that is in excess of 27 cents for the first 5,000 kilometres and 21 cents for the remaining kilometres.  ... By virtue of subparagraph 6(1)(b)(v) of the Act, a reasonable allowance for travelling expenses received by an employee from his employer in respect of a period when he was employed in connection with the selling of property or negotiating of contracts for his employer, is excluded from employment income. ...

Short (613) 957-2134 19(1) November 6, 1989 Dear Sirs: Re: Automobile Allowances This is in reply to your letter dated July 14, 1989, wherein you have requested an interpretation of subparagraph 6(1)(b)(v) and paragraph 18(1)(r) of the Income Tax Act (the "Act") in connection with the following situation: A commission based employee receives an automobile allowance that is in excess of 27 cents for the first 5,000 kilometres and 21 cents for the remaining kilometres. ... By virtue of subparagraph 6(1)(b)(v) of the Act, a reasonable allowance for travelling expenses received by an employee from his employer in respect of a period when he was employed in connection with the selling of property or negotiating of contracts for his employer, is excluded from employment income. ...

You have requested an advance income tax ruling with respect to the taxability of legal and accounting fees paid by XXXX in connection with charges and being laid by Revenue Canada, Taxation against XXXX under the authority of section 242 of the Income Tax Act (the "Act") in the hands of, XXXX as a benefit under either paragraph 6(1)(a), subsection 15(1) of alternatively, subsection 246(1) of the Act. ... With respect to your request for an opinion regarding payments of legal and accounting fees already made, we make reference to Interpretation Bulletin IT-99R3- Legal and Accounting Fees, which sets out at paragraph 19 the Department's position with respect to fees incurred in connection with a prosecution under section 239 of the Act. ...

In that situation you stated that Canada would be taxing income from the use of Canadian situs property which has a clear connection to Canada. Since there is no clear connection with Canadian property in the subsection 15(1) situation, you are of the view that the logic of Canada imposing any kind of tax appears far more tenuous. ...

All contributions made under the EBP after the establishment of the Statutory Arrangement and all property that can reasonably be considered to derive from those contributions are deemed to be property held in connection with the Statutory Arrangement and not in connection with the Existing Arrangement. ...