Search - connection

Reasons: It appears that the training in this case is done on reserve, which would create a sufficient connection to the reserve to make the amount tax-exempt. ... However, a sufficient connection to a reserve can be said to exist and the exemption becomes available when the training is actually taken on a reserve. ...

Reasons: The wording of the definition of an RCA in subsection 248(1) of the Act requires that the plan or arrangement be funded in connection with benefits that are to be, or may be, received or enjoyed on, after or in contemplation of a substantial change in services rendered, retirement or loss of employment. ... Our Comments Subject to certain listed exclusions, an RCA is defined in subsection 248(1) of the Act as 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. ...

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... ...

No evidence of any connection between the assumption by the corporate taxpayer of the mortgage and the acquisition by it of the common shares. ... While the corporate taxpayer did acquire shares of public corporations in an earlier transaction and as consideration issued corporate indebtedness to its shareholder, we are not aware of any evidence that there was any connection between the subsequent assumption by the corporate taxpayer of its shareholder's mortgage and the acquisition of any property, including the public shares. ...

Application of subsection 126(4) As the Kyrgyz Republic will, under the Contract, only subject XXXXXXXXXX employees to personal tax if those individuals can claim a foreign tax credit, it is our view that subsection 126(4) will be applicable in the situation such that no foreign tax credit will be available for income taxes paid to the Kyrgyz Republic in respect of employment income earned by XXXXXXXXXX employees in connection with the Contract. ... However, see above for the application of the Convention to employment income earned by Canadian residents in the Kyrgyz Republic in connection with the Contract. ...

Definition of a "qualifying educational program" does not include any program taken by a student during a period in respect of which the student receives income from an office or employment and in connection with that office or employment. ... However, it is noted that a qualifying educational program does not include any such program if a student takes the program, (i) during a period in respect of which the student receives income from an office or employment, and (ii) in connection with, or part of the duties of, that office or employment. ...

In our view, the costs and expenses of training, including those for travel, food, and lodging incurred in connection with attending a university to obtain a doctorate degree are not deductible as current expenses. Further to paragraph 2 of Interpretation bulletin IT-357R2, training costs incurred by a taxpayer in connection with a course which he or she takes to obtain a degree, diploma or professional qualification or similar certificate would be considered capital in nature. ...

Principal Issues: (1) The taxability of an allowance paid to an employee with respect to an employee owned computer used in connection with the employee's duties. (2) Where the employer decides to rent the computer from the employee, would subsection 6(3) of the Act deem the amount to be employment income rather than rental income. ... August 31, 2001 Dear XXXXXXXXXX: Re: Employee Computer Allowance We are writing in response to your letter dated July 11, 2001, wherein you requested a ruling on: (1) The taxability of an allowance paid to an employee with respect to an employee owned computer used in connection with the employee's duties, and (2) Where the employer decides to rent the computer from the employee, would subsection 6(3) of the Income Tax Act (the Act) deem the amount to be employment income rather than rental income. ...

With respect to your employment, you have referred to form T2200 in connection with a deduction of a substitute or an assistant. ... On the basis of the information you provided, we are providing comments on the deduction in paragraph 8(1)(f) of the Income Tax Act (the "Act") which, in broad terms, relates to individuals who are employed in connection with the selling of property or negotiating contracts for their employers and are paid by commissions. ...

In connection with your concern, you have indicated that medical doctors who are employees should be entitled to deduct such contributions as you believe that self-employed medical doctors are entitled to deduct them. ... We assume the employees in the situation submitted are not employed in connection with the selling of property or negotiating of contracts for their employer. ...