Search - connection

Position: It depends on the strength of the connection between the employment insurance benefits and the fishing income. ... The trial judge in Williams noted that the connection between the benefits and the qualifying employment was strong because the benefits are based on premiums arising from the previous employment. ... The Queen, 2011 DTC 1314), the courts held that given the connections between the fishing income and the reserve, the fishing income was situated on the reserve and therefore exempt from income tax, despite the delivery of fish off the reserve. ...

Reasons: The payment is for the use of the copyrighted photograph and not on account or in lieu of payment of, or in satisfaction of, payment for a right in, or to the use of, a motion picture film, or a film, video tape or other means of reproduction for use in connection with television. ... This letter will address the circumstances in which the Payments are for the use of the photographs in connection with television in Canada (for example in a backdrop to a film clip used in a television program that is to be used or reproduced in Canada). ... " For ease of reference, hereafter the phrase "a film, video tape or other means of reproduction for use in connection with television" as they appear in 212(5)(b) above, will be referred to as Television Product. ...

Dependent on whether the extension or renewal period is considered to be in connection with the original commitment made by the employer. 3. ... The phase-out rules will not apply with respect to qualifying foreign employment income earned by an employee in connection with a project or activity to which the employee's employer had committed in writing before March 29, 2012. ... Whether the QFEI is earned in connection with a contract that was committed to in writing before March 29, 2012, is one of fact that can only be determined on a case-by-case basis. ...

Principal Issues: Whether the ECE of a son who acquires eligible capital property from a corporation controlled by his parents would be subject to a reduction under subsection 14(3) of the Act based on an earlier claim for capital gains exemption made by the parents in connection with the disposition the corporation. ... Reasons: The ECE reduction under ss 14(3) of the Act takes into account capital gains exemption claimed by a person not dealing at arm's length in connection with an earlier disposition by that person to a person not dealing at arm's length. ... This is because the ECE reduction under subsection 14(3) of the Act takes into account any capital gains exemption claimed by another person with whom the transferee (in this case, the second transferee) was not dealing at arm's in connection with an earlier disposition of the same eligible capital property. ...

29 February 2016 External T.I. 2015-0614151E5- Deductibility of Actuarial Fees CRA Tags 18(1)(a) 18(1)(b) 18(1)(h) 60(o.1) Principal Issues: Whether actuarial fees incurred in connection with the division of pension benefits on marriage or common-law partnership breakdown are deductible in computing income? ... Podor February 29, 2016 Dear XXXXXXXXXX: Re: Deductibility of Actuarial Fees We are responding to your correspondence dated October 20, 2015 concerning the deductibility of actuarial fees incurred in connection with the division of pension benefits on marriage breakdown. ... Expenses (such as legal or actuarial fees) incurred in connection with the division or settlement of a right to pension benefits arising out of, or on a breakdown of, a marriage or common-law partnership are considered to be on account of capital. ...

Principal Issues: Deductibility of sales commission expenses incurred by mutual fund limited partnerships in connection with the distribution of mutual funds. ... Thompson Attention: XXXXXXXXXX March 10, 1995 Dear Sirs: Re: Mutual Fund Limited Partnerships This is in reply to your facsimile transmission dated February 21, 1995 concerning the deductibility of sales commission expenses incurred by mutual fund limited partnerships in connection with the distribution of mutual funds. ... As noted therein, a limited partnership which incurs sales commission expenses in connection with the distribution of mutual funds before June 30, 1995 will be allowed to amortize these expenses in the following manner. ...

Principal Issues: An individual, in connection with his or her wedding consulting business, purchases a tuxedo. The tuxedo is worn to weddings in connection with the individual’s business. ... You have indicated that you operate a wedding consulting business and that you wear a tuxedo when you are present at a wedding in connection with your business. ...

10 June 1991 Internal T.I. 91M06217 F- Overseas Employment Tax Credit Unedited CRA Tags 122.3, 122.3(1)(b)(i) Dear Sirs: This is in reply to your letter dated March 7, 1991 whereby you requested our opinion as to whether an employee would be considered to perform the duties of his employment in   24(1)  in connection with a contract under which the employer carries on business in    for the purposes of qualifying for the overseas employment tax credit provided under section 122.3 of the Income Tax Act (the "Act"). ... Our Comments An individual (employee) must have performed all or substantially all the duties of his employment in one or more countries other than Canada in connection with a contract under which the specified employer carried on business in such other country or countries with respect to the exploration for or exploration of petroleum, natural gas, minerals or other similar resources.  ... In order for us to reach a conclusive opinion on such a transaction, we could have to review the contract itself and its connection, if any, with Canco's acquisition of the 24(1)  In the event this hypothetical example becomes a contemplated transaction, any request for a technical interpretation should be in the form of a request for an advance income tax ruling in accordance with the Information Circular 70-6R2 dated September 28, 1990.  ...

7 June 1991 Income Tax Severed Letter- Overseas Employment Tax Credit Unedited CRA Tags 122.3 Dear Sirs: This is in reply to your letter dated March 7, 1991 whereby you requested our opinion as to whether an employee would be considered to perform the duties of his employment in XXX in connection with a contract under which the employer carries on business in XXX for the purposes of qualifying for the overseas employment tax credit provided under section 122.3 of the Income Tax Act (the "Act"). ... XXX Our Comments An individual (employee) must have performed all or substantially all the duties of his employment in one or more countries other than Canada in connection with a contract under which the specified employer carried on business in such other country or countries with respect to the exploration for or exploitation of petroleum, natural gas, minerals or other similar resources. ... In order for us to reach a conclusive opinion on such a transaction, we would have to review the contract itself and its connection, if any, with Canco's acquisition of the XXX. ...

The expressions "in connection with" and "with respect to" are considered to have very broad meanings such that the activities described in (a) to (f) above would appear to be qualifying activities. The activities that are engaged by the employers in connection with the XXXXXXXXXX, as described in (g) above, do not appear to qualify as qualifying activities. In the event that the employers’ activities consist of both qualifying and non-qualifying activities, it will be necessary to establish that the XXXXXXXXXX employees performed all or substantially all their duties in connection with the qualifying activities for them to be entitled to the OETC. ...