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Results 381 - 390 of 5529 for connection
Technical Interpretation - External

13 June 1996 External T.I. 9611935 - PRINCIPAL RESIDENCE EXEMPTION

In 1994 the individual moved to Ontario in connection with a employment position. ... However, in November 1994, you moved to a location in Ontario in connection with an employment position. ...
Ruling

2096 Ruling 9600363 - RELATED BUSINESS

We understand that to the best of your knowledge and that of the taxpayers involved, none of the issues involved in the requested rulings is being considered by a District Taxation Office or a Taxation Centre in connection with a tax return already filed, and none of the issues involved in the requested rulings is the subject of any notice of objection or is under appeal. ... XXXXXXXXXX would use these funds to cover expenses associated with product development and marketing, and would distribute the balance to the XXXXXXXXXX which are also registered charities with missions virtually identical to that of the XXXXXXXXXX. 8.Third party commercial interests, for example, XXXXXXXXXX would derive revenues from their activities in connection with the products. 9.These endeavours would be undertaken on a semi-regular basis, but each would have a limited period of effectiveness. ...
Technical Interpretation - Internal

2 October 1996 Internal T.I. 9631017 - RETIRING ALLOWANCE, DAMAGES

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. ...
Technical Interpretation - External

6 May 1993 External T.I. 9300635 F - Amendment of Group Life Insurance Policy

In connection with your request, you have enclosed a copy of the standard form of group life insurance policy which you have issued as well as a copy of a draft special terminal illness benefit provision which you intend to add thereto. ... It appears that there may be some confusion but to clarify, the Department may provide general comments in connection with hypothetical situations but such comments are not binding on the Department and may not necessarily apply in the context of a specific situation (and our replies will so state). ...
Technical Interpretation - External

7 March 1995 External T.I. 9428355 - ACTIVE SHAREHOLDER BONUSES

Revenue Canada's policy on the deduction of bonuses, as discussed at the 1981 Canadian Tax Foundation Conference, is that a bonus will not be considered unreasonable where the recipient is a principal shareholder-manager of the corporation and the corporation's general practice is to distribute its profits to shareholder-managers in the form of bonuses or the company has adopted a policy of declaring bonuses to shareholders to remunerate them for the profits the corporation has earned that are attributable to the special know-how, connections or entrepreneurial skills of the shareholders (1981 Roundtable, question 42). ... If, however, it can be demonstrated that salaries and bonuses paid to persons is to remunerate them for the profits the company has earned that are, in fact, attributable to the special know-how, connections, or entrepreneurial skills of those persons, the test will be considered to have been met. ...
Technical Interpretation - Internal

12 April 1995 Internal T.I. 9509366 - INTER. OF "IN RESPECT OF SERVICES RENDERED BY T/P"

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 Letter

5 January 1995 Ministerial Letter 9433288 - INDIAN EMPLOYMENT INCOME EXEMPTION WILLIAMS

You state that XXXXXXXXXX is a national non-profit organization dedicated to XXXXXXXXXX XXXXXXXXXX Guideline 4 will apply to exempt all the employment income of an Indian, as defined for the purposes of the Indian Act, regardless of where their employment duties are performed, where a) the employer is resident on the reserve; b) the employer is an Indian band, tribal council or an Indian organization controlled by one or more such bands or tribal councils, if the organization is dedicated exclusively to the social, cultural, educational or economic development of Indians who for the most part live on reserves; and c) the duties of the employment are in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserves. ... I would also like to point out that the employment duties of each particular Indian employee must be considered to determine if they were in connection with the employer's non-commerical activities carried on exclusively for the benefit of Indians who for the most part live on reserves. ...
Technical Interpretation - External

7 October 2003 External T.I. 2003-0034225 - northern residents deduction

Generally, the deduction in respect of employee travel benefits provided in paragraph 110.7(1)(a) of the Act, 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 traveling expenses in connection with not more than two other trips per year. ... " In our view, for purposes of paragraph 110.7(1)(a) of the Act, there must be a connection between the actual traveling expenses incurred by a taxpayer or a member of the taxpayer's household and the amounts paid by the taxpayer's employer to defray those costs, in order for the amounts to be "...in respect of travel expenses incurred by the taxpayer... ...
Miscellaneous severed letter

2003 Income Tax Severed Letter 2003-0035701 - Supp. Ruling - Minor Changes

In connection with these corporate transactions, DC will distribute to TC1 the excess of the TC1 Consideration Notes and the TC1 Redemption Notes over the fair market value of 1 common share of DC and to TC2 the excess of the TC2 Consideration Notes and the TC2 Redemption Notes over the fair market value of 1 common share of DC. ... In connection with the winding-up of DC, DC will distribute to TC1 the remainder of the TC1 Consideration Notes and the TC1 Redemption Notes and XXXXXXXXXX Class "B" shares of Subco1 and DC will distribute to TC2 the remainder of the TC2 Consideration Notes and the TC2 Redemption Notes and XXXXXXXXXX Class "B" shares of Subco1. ...
Technical Interpretation - Internal

31 October 2003 Internal T.I. 2003-0038897 - GIFT OF SHARES

They import such means 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. ...

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