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(2) If an employee does not provide receipts for advances from employers for professional development (PD) travel expenses, should the advances should be reported on these particular employees' T4 slips. (3) If the Employer reimburses an employee for the cost of travel in connection with PD travel, but treats the reimbursement as a non-taxable benefit, can the employee claim the deduction on their personal income tax return? ... In your letter, you raised three questions in relation to travel undertaken by employees of XXXXXXXXXX (the "Employer") in connection with the employees' professional development ("PD"). ... If the Employer reimburses an employee for the cost of travel in connection with PD travel, but treats the reimbursement as a non-taxable benefit, can the employee claim the deduction on their personal income tax return? ...

The Queen, [1983] 2 S.C.R. 428 to be "probably the widest of any expression intended to convey some connection between two related subject matters"; and (3) whether or not a non-resident is liable for tax in Canada is not relevant in determining whether a person must withhold pursuant to subsection 105(1) of the Regulations. Accordingly, any connection between services rendered in Canada and a commission paid by a person to a non-resident may be sufficient to trigger the withholding requirement in subsection 105(1) of the Regulations. For this reason, and because your letter is not clear regarding the details of the connections between the payment of the commission and any services that may be rendered in Canada by you, in your capacity as "paymaster", or any non-resident, it is our view that you should either withhold fifteen per cent from any payment of a commission to any non-resident or attempt to obtain a Treaty-Based Waiver. ...

We also acknowledge the information provided in subsequent correspondence and during our various telephone conversations in connection with your request (XXXXXXXXXX). We understand that, to the best of your knowledge and that of the taxpayer referred to above, none of the issues involved in the ruling request is: (i) in an earlier return of the taxpayer or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or a related person; (iii) under objection by the taxpayer or a related person; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (v) the subject of a ruling previously issued by the Directorate. ... Definitions The following terms have the meanings specified: (a) "disposition time" has the meaning prescribed in paragraph 149(10)(b) and more specifically, means the time that is immediately before the time that is immediately before the time that Opco ceases to be exempt from tax under Part I connection with the transactions described in paragraph 4 below; (b) XXXXXXXXXX; (c) XXXXXXXXXX; (d) "Opco" means XXXXXXXXXX; (e) XXXXXXXXXX; (f) XXXXXXXXXX; and (g) "reacquisition time" means the time that Opco ceases to be exempt from tax under Part I as a consequence of the transactions described in paragraph 4 below. ...

Reimbursements or awards for legal fees in connection with the collection or establishing a right to income from employment: Reimbursements or awards for legal fees in connection with the collection or establishing a right to income from employment are included in income from an office or employment by virtue of paragraph 6(1)(j) of the Income Tax Act (the "Act"). ... Reimbursements or awards for legal fees in connection with the collection or establishing a right to a retiring allowance: Paragraph 56(1)(l.1) of the Act requires a taxpayer to include in computing income amounts received as an award or reimbursement of legal expenses paid to collect or establish a right to a retiring allowance. ...

We also acknowledge the information provided in subsequent correspondence and during our various telephone conversations in connection with your request (XXXXXXXXXX). We understand that to the best of your knowledge and that of the taxpayers involved: i) none of the issues involved in the requested ruling is being considered by any District Tax Services Office or Taxation Centre of the Department in connection with a tax return already filed, and ii) none of the issues involved in the requested ruling is the subject of any notice of objection or is under appeal. ... COMMENTS Except as expressly stated herein, nothing in this ruling should be construed as implying that Revenue Canada Customs, Excise and Taxation has accepted, approved or confirmed any income tax implications in connection with the facts or proposed transactions referred to herein. ...

Principal Issues: Are legal fees deductible when they are incurred in connection with the issuance of a child support order under the Divorce Act? ... In your letter you have requested clarification of the Department’s position on the deductibility of legal fees incurred in connection with the issuance of a child support order. ... As a further comment, it remains our view that legal fees incurred in connection with spousal maintenance are not deductible because the courts do not have the same discretion with child maintenance as the courts have with spousal maintenance under the Divorce Act. ...

The criteria required to be met in order for the program to qualify as a “qualifying educational program” are set out in subsection 118.6(1) of the Act but excludes any such program “(b) if the program is taken by the student (i) during a period in respect of which the student receives income from an office or employment, and (ii) in connection with, or as part of the duties of, that office or employment.” XXXXXXXXXX, it is our view that the term “in connection with” has a broader meaning than the adjoining phrase contained in (ii) above, “as part of the duties of” and would include any students who are employed in an accounting related field. ... It should also be noted that the requirements of paragraph (b) of the definition of “qualifying educational program”, in subsection 118.6(1) of the Act, also apply to the proposed definition of “specified educational program” in subsection 118.6(1), such that our above comments with respect to the term “in connection with” would also apply to part-time students. ...

The criteria required to be met in order for a program to qualify as a “qualifying educational program” are set out in subsection 118.6(1) of the Act (and explained in IT-515R2), but exclude any such program “(b) if the program is taken by the student (i) during a period in respect of which the student receives income from an office or employment, and (ii) in connection with, or as part of the duties of, that office or employment.” It is our view that the term “in connection with”, in (ii) above, has a broad meaning, such that it would apply to XXXXXXXXXX students who are employed in XXXXXXXXXX related field. ... As a result, the requirements of paragraph (b) of the definition of “qualifying educational program” also apply to the proposed definition of “specified educational program” in subsection 118.6(1), such that our above comments with respect to the term “in connection with” would also apply to part-time students. ...

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. ... Paragraphs 221(1)(b) and (d) of the Act authorize the Governor in Council to make regulations prescribing “the evidence required to establish the facts relevant to assessments under this Act” and “requiring any class of persons to make information returns respecting any class of information required in connection with assessments under this Act”. ...

Paragraph 8308.1(2)(b) applies where the services were rendered in a period throughout which the individual was resident in Canada and the services that were rendered to the employer were primarily rendered in Canada, or in connection with a business carried on by the employer in Canada. Since your situation does not involve services rendered in Canada, and is not in connection with a business carried on by the employer in Canada, paragraph 8308.1(2)(b) does not apply and the employee's pension credit with respect to that employer (and therefore his pension adjustment) is nil. ... A retirement compensation arrangement ("RCA") is defined in subsection 248(1) of the Act to be a plan or arrangement under which contributions are made by an employer or former employer of a taxpayer to another person (a "custodian") in connection with benefits that are to be, or may be, received or enjoyed by any person on, after or in contemplation of any substantial change in the services rendered by the taxpayer, the retirement of the taxpayer, or the loss of an office or employment of the taxpayer. ...