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Parnanzone Manager (613) 957-9232      EACC9734 SUBJECT: DRAFT FORM "Designation of Retiring Allowances as Qualifying Transfers in Connection with a Past Service Event in Respect of a Defined Benefit Provision of a Registered Pension Plan" This is in reply to your round trip memorandum of August 24, 1990 concerning the review of the above-noted form. ...

For the SR & ED to be related to a business of the taxpayer, there must be some connection or link between the taxpayer's business carried on at the time the expenditure is made and the SR & ED carried on.  ...

Therefore services provided by a foreign affiliate to a taxpayer in connection with either a guarantee or a warrantee associated with a product sold by the taxpayer would not qualify for the exclusion under paragraph 95(3)(b) as having been performed in connection with the sale of goods. ... The Queen, 83 DTC 5041 (SCC), you have submitted that the words "in connection with", found in paragraph 95(3)(b), convey only some connection between two related subject matters, not necessarily a direct connection". 1 And on that basis you submit that the manufacturing and processing services described herein should be considered services performed in connection with the sale of goods by Canco. ... They import such meanings as "in relation to", "with reference to" or "in connection with". ...

Whether the work done by NRco could be considered to be "in connection with the exploration for or exploitation of the minerals... ... They import such meanings as "in relation to", "with reference to" or "in connection with". ... Our view is that even if we give to the terms "in connection with" the widest scope possible, the activities performed under the Program could not be considered to be performed "in connection with" or "in respect of" the exploration for or exploitation of the resources. ...

Distance travelled which is not personal in nature (in relation to the employer's business) is considered to be in connection with or in the course of employment; other distance travelled is not. 2&3.     While the activity of engaging in an employment-related telephone call on a mobile phone may constitute an activity that is in connection with employment, it does not follow that the distance travelled by the automobile while the driver is so engaged is also in connection with or in the course of employment. 4&5.      ... In summary, it is our position that personal travel as described in paragraph 5 of IT-63R3 cannot be converted to travel 'in connection with or in the course of employment' by the concurrent use of a mobile phone for employment purposes. ...

Distance travelled which is not personal in nature (in relation to the employer's business) is considered to be in connection with or in the course of employment; other distance travelled is not. 2&3. While the activity of engaging in an employment-related telephone call on a mobile phone may constitute an activity that is in connection with employment, it does not follow that the distance travelled by the automobile while the driver is so engaged is also in connection with or in the course of employment. 4&5. ... In summary, it is our position that personal travel as described in paragraph 5 of IT-63R3 cannot be converted to travel in connection with or in the course of employment' by the concurrent use of a mobile phone for employment purposes. ...

Distance travelled which is not personal in nature (in relation to the employer's business) is considered to be in connection with or in the course of employment; other distance travelled is not. 2&3. While the activity of engaging in an employment-related telephone call on a mobile phone may constitute an activity that is in connection with employment, it does not follow that the distance travelled by the automobile while the driver is so engaged is also in connection with or in the course of employment. 4&5. ... In summary, it is our position that personal travel as described in paragraph 5 of IT-63R3 cannot be converted to travel `in connection with or in the course of employment' by the concurrent use of a mobile phone for employment purposes. ...

Principal Issues: (a) Is an allowance for the use of a motor vehicle in connection with the duties of an office or employment, based on a per-kilometer amount, a taxable benefit when it is adjusted to a minimum amount per round trip? (b) Is an allowance for the use of a motor vehicle in connection with the duties of an office or employment, based on a per-kilometer amount, a taxable benefit when in the previous month an employee may have received a fixed amount plus a per-kilometer amount allowance? ... Further, the fixed rate allowance for travel within the employment district is taxable since it is not based solely on the number of kilometers for which the vehicle is used in connection with or in the course of the office or employment. ...

The phrase "in connection with or in the course of the office or employment" is not defined in the Act. ... The Concise Canadian Oxford Dictionary does not define the phrase "in connection with or in the course of the office or employment" but does define the phrases "in connection with" and "in the course of". This dictionary defines "in connection with" as "with reference to" and defines "with reference to" as "regarding; as regards". ...

Tax Treaty Principal Issues: 1) Would income derived "in connection with" a U.S. trade or business include income derived from a "complementary business" as described in the 2006 U.S. ... Position: 1) Yes- in determining whether Canadian-source income is derived in connection with an active U.S. trade or business the CRA will be guided by the Technical Explanation to Article XXIX A(3) of the Canada-U.S. ... Model Income Tax Convention; 2) A portion of the gain would be considered not to be derived in connection with the U.S. trade or business. ...