Search - connection

They import such meanings as "in relation to", "with reference to" or "in connection with". ... 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". ...

26 May 2010 External T.I. 2009-0342961E5- Computation of the RRIF Minimum Amount Unedited CRA Tags 146.3(1) Principal Issues: How is the minimum amount calculated when the property held in connection with a RRIF has no value? ... You have requested clarification of the calculation of the minimum amount under the RRIF if the fair market value of all the properties held in connection with the RRIF is nil. ... The determination of the fair market value of all properties held in connection with the RRIF is a question of fact. ...

X remains an employee of ACo but also has an opportunity for employment with Canco in Canada in connection with a directional drilling contract secured by Canco with a person unrelated to Aco. ... When the aggregate of the employment duties performed outside Canada in connection with ineligible activities and those performed in Canada in connection with any activity represent more than 10% of all the employment duties, the individual will not meet the "all or substantially all" test. ... X outside Canada in connection with his employment with ACo is 90% or more of all of his employment duties performed for ACo during a qualifying period, Mr. ...

Our position is: (a) The phrase "for use in connection with television" as used paragraph 212(5)(b) of the Act is not limited to television broadcasting. The only restriction on the application of paragraph 212(5)(b) is where a film, videotape or other means of reproduction for use in connection with television is solely in connection with and as a part of a news program produced in Canada. ... Royalties in respect of the production or reproduction of motion pictures or videotapes which are not for private (home) use, including but not limited to those used in connection with television broadcasting, are not exempt. ...

What are to be considered activities that would be carried on in Canada in connection with the exploration or exploitation of the seabed and subsoil and their natural resources ("in connection with the offshore resources")? ... Transportation activities (e.g. ferrying of supplies and personnel) in connection with the offshore resources fall within paragraph 2 of Article XXVIIA. ... The wording "in respect of an employment exercised aboard a tugboat or similar vessel in connection with such activities" as used in paragraph 5(b) is unclear. ...

What are to be considered activities that would be carried on in Canada in connection with the exploration or exploitation of the sea bed and subsoil and their natural resources ("in connection with the offshore resources")? ... Transportation activities (e.g. ferrying of supplies and personal) in connection with the offshore resources fall within paragraph 2 of Article XXVIIA. ... The wording "in respect of an employment exercised aboard a tugboat or similar vessel in connection with such activities" as used in paragraph 5(b) is unclear. ...

Principal Issues: Whether debts "incurred in connection with the purchase and sale of investments... ... Our Comments Paragraph 149.1(4)(d) of the Income Tax Act refers to a debt "incurred in connection with the purchase and sale of investments... ... In particular, in our view, loans obtained or debts incurred for the purpose of permitting a public or private foundation to purchase investments are not debts "incurred in connection with the purchase and sale of investments". ...

To function as a cogeneration system, each micro-turbine requires a connection to the gas supply, electrical, primary heating and control systems of the greenhouse. ... With regard to the natural gas connection, the gas main to the greenhouse does not only serve the micro-turbine units, and the system boundary for the gas connection is where the gas enters the micro-turbine units. Therefore, in our view, none of the costs of the gas supply connections are eligible for Class 43.1. ...

Reasons: It had been our view that the phrase "debts incurred in connection with the purchase and sale of investments" should be interpreted strictly. ... In a memorandum to you dated June 30, 2005, we discussed the meaning of the phrase "debts incurred in connection with the purchase and sale of investments" in paragraphs 149.1(3)(d) and (4)(d) of the Income Tax Act. ... Jurisprudence has confirmed that the phrase "in connection with" has a very broad meaning (see the Supreme Court of Canada commentary in that regard in Nowegijick v. ...

Reasons: Considered incidental, connection insufficient. December 8, 1998 Client Services Directorate HEADQUARTERS Ministerial Correspondence Division D. ... Where less than 90% of the duties are performed on a reserve the exemption can be prorated, however, there still must be a sufficient connection to consider that part of the employment is situated on the reserve. ... Where the time on the reserve consists of irregular intervals of short amounts of time, we would likely consider the connection to be incidental and, therefore, the income would be fully taxable. ...