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Technical Interpretation - External

13 July 2010 External T.I. 2009-0348951E5 - Taxation of payments made by union to its members

In this context, the words "in respect of" have been held by the Courts to imply a connection between the loss of employment and the subsequent receipt, where the primary purpose of the receipt was compensation for the loss of employment. (See also ¶ 11) Two questions set out by the Courts to determine whether a connection exists for purposes of a retiring allowance are as follows: 1- But for the loss of employment would the amount have been received? ...
Technical Interpretation - External

22 February 2011 External T.I. 2010-0374421E5 - Motion Picture Copyright Royalties

Similarly, paragraph 212(1)(b) imposes a 25 per cent withholding tax on amounts paid or credited to a non-resident for the use of a film, video tape or other means of production or reproduction for use in connection with television, where such film or tape has been or is to be used or reproduced in Canada. ... This exemption at source does not apply to copyright royalties in connection with television broadcasting. ...
Technical Interpretation - External

9 December 2010 External T.I. 2010-0379831E5 - Employee release and settlement agreement

In this context, the words "in respect of" have been held by the Courts to imply a connection between the loss of employment and the subsequent receipt, where the primary purpose of the receipt was compensation for the loss of employment. ... Two questions set out by the Courts to determine whether a connection exists for purposes of a retiring allowance are as follows: 1- But for the loss of employment would the amount have been received? ...
Technical Interpretation - External

19 August 2010 External T.I. 2010-0371151E5 - Grants and Awards

Given the purpose of a payment under the XXXXXXXXXX (and provided the amount is not received in connection with employment), we are of the view that the payment could be viewed as scholarship income of the recipient. It should be noted that a student may be able to claim a scholarship exemption under subsection 56(3) for the full amount of a scholarship provided it was received in connection with the student's enrolment in an educational program that entitles the student to the Education Tax Credit. ...
Technical Interpretation - External

29 May 2009 External T.I. 2009-0313571E5 - Eligible expenditures - home renovation tax credit

You have described three scenarios for hot tub purchases: The 'plug in product' type of hot tub comes with the cord connected and ready to use, without the need of a permanent electrical connection. ... The customer is completing a back yard renovation that includes new decking, site preparation (as described immediately above) for a hot tub as well as the electrical connection for the hot tub. ...
Technical Interpretation - External

19 June 2009 External T.I. 2009-0313051E5 - Prescribed Prize

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. ...
Ministerial Correspondence

10 June 2009 Ministerial Correspondence 2009-0320691M4 - In-kind RRSP withdrawals and TFSA contributions

In this regard, the income tax rules do not obligate financial institutions to accept in-kind transactions in connection with RRSPs and TFSAs, nor do the rules regulate the level of fees charged in connection with these registered accounts. ...
Technical Interpretation - Internal

13 January 2010 Internal T.I. 2009-0345021I7 - Costs of a Missionary Trip

January 13, 2009 Dear XXXXXXXXXX: Re: Costs of a Volunteer on a Missionary Trip This is in response to your letter dated October 20, 2009, wherein you asked whether there are any tax breaks where an individual (the "Taxpayer"), as part of a missionary trip, volunteered to assist in the construction of a XXXXXXXXXX and incurred travel and other related expenses in connection with that trip. ... While a question of fact, it appears that the Taxpayer has not incurred the particular expenditures in connection with any employment or business carried on by him. ...
Technical Interpretation - External

10 March 2010 External T.I. 2009-0349531E5 - Northern residents deduction

., they must have some close connection to each other) so that it is reasonable to conclude that such persons are members of the taxpayer's household. ... " It is our view that "a member of a taxpayer's household" for the purposes of subsection 110.7(1)(a) of the Act should only include individuals who are living together as a family unit (i.e., the individuals must have some close connection with one another) in the same self-contained domestic establishment. ...
Technical Interpretation - External

6 October 2008 External T.I. 2008-0290421E5 - Education Credit- Reimbursement

For years prior to 2004, the former definition of "qualifying educational program" in the Income Tax Act (the "Act") excluded any program taken by a 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. ... This means that provided all other requirements are met, a course or program taken by an individual in connection with his or her employment and during which time the individual received income from that employment is a "qualifying educational program" eligible for the education tax credit. ...

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