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In this connection, as set out in paragraph 9 of IT-159R2, the determination of when a debt becomes a bad debt is a question of fact. ... In this connection it is our view that a taxpayer, in the circumstances described above, would be able to avail himself of the provisions of subsection 50(1) of the Act when it can be shown that the whole amount of the debt is uncollectable or when a portion of it has been settled and the remainder is uncollectable. ...

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. ...

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... ...

Guideline 4 also requires that the duties of the employees be in connection with the employer's non-commercial activities. ... In any event, it is not clear to us that all the employees of this new office will be completing their duties in connection with non-commercial activities. ... Those employees completing duties in connection with the commercial operations of the Band Office would not be eligible for an exemption from income tax on their employment income under Guideline 4. ...

In the situation described above, the issue is whether the connection between Mr. ... In our view, the connection is sufficient to satisfy the purpose requirement of subparagraph 40(2)(g)(ii) of the Act. ... E and potential dividend income from Opco2, then this connection would be sufficient to satisfy the purpose requirement of subparagraph 40(2)(g)(ii) of the Act. ...

The Fund will acquire Assigned Interests in connection with what is described in the Credit Agreement as a Canadian Term Facility and a US Term Facility. ... The Fund will also acquire a Participation Interest in connection with what is described in the Credit Agreement as a Canadian Term Facility and a US Term Facility. ... (b) The right to be indemnified for losses and expenses arising in connection with a default under the Loan (Section XXXXXXXXXX of the Credit Agreement). ...

Although section 94.2 is a relatively new provision of the Act, the question of how to compute FAPI in circumstances where complete and full information may not be accessible is not novel, as it has historically been relevant in connection with CFA status under former subparagraph 94(1)(d) (the predecessor of current section 94.2) and paragraph (b) of the definition of "controlled foreign affiliate" in subsection 95(1). ... Additional relief in connection with reporting requirements may be available on a case-by-case basis under subsection 220(2.1). ... Effectively, section 94.2, in conjunction with subsection 233.4(4), although with some expansion to the number of foreign entities subject to the provisions' requirements, maintains and accords with the policy announced by the Department of Finance in Budget 2010 of retaining and broadening the reporting requirements in connection with prior subsection 94(1). ...

This amount could be further reduced if the employee is required by the employer to use the automobile in connection with or in the course of the office or employment and the distance travelled is primarily in connection with or in the course of that office or employment. ...

It appears that one of the main purposes for the existence of the corporation may be to serve as an artificial connection between the investment income of the Indian investors and a reserve, by acting as an intermediary between the Indians and their investments in securities listed on a stock exchange. It is our view that where an arrangement creates an artificial connection between income and a reserve, the arrangement will carry no weight as a connecting factor. ... In this regard, it should be noted that it is our view that where an arrangement creates an artificial connection between income and a reserve, the arrangement will carry no weight as a connecting factor. ...

Reasons: (1) (A) Location where the services are performed is the most significant connection in this case. Location of the sole client is relevant except when it can reasonably be considered that one of the main purposes for the establishment of the business-client relationship with the band is to serve as a connection between the logger's business income and a reserve. (1) (B) Same reason as (1)(A). (2) Same reason as (1)(A). (3) Sourcing of royalty income is discussed in paragraph 32 of IT-270R2. ... In such a circumstance, in our view, it must be taken into consideration that where an arrangement creates an artificial connection between business income and a reserve, the arrangement will carry no weight as a connecting factor. ...