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Finally, the employee's duties of employment must be 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. Given the nature of the employer, it is questionable whether the duties of employment of the employees are in connection with the non-commercial activities of the employer. It also seems unlikely that the duties of employment of the employees working for the Organization are in connection with activities carried on exclusively for the benefit of Indians who for the most part live on a reserve. ...

To qualify for the OETC, a Canadian resident individual must: (a) be employed by a specified employer (generally, a resident of Canada), other than for the performance of services under a prescribed international development assistance program of the Government of Canada: (b) be employed in connection with a contract (or for the purpose of obtaining such a contract) under which the specified employer carried on business outside Canada with respect to the exploration for or exploitation of petroleum, natural gas, minerals or other similar resources, with respect to any construction, installation, agricultural or engineering project or with respect to an activity performed under contract with the United Nations; and (c) have performed all or substantially all the employment duties in connection with the contract outside Canada. ... During a period of absence from a work location outside Canada, an individual may take vacation time, consult with the specified employer in Canada or perform duties of employment in Canada and still remain eligible for the OETC provided that, throughout the period, substantially all of the individual's employment duties (90% or more) are performed outside Canada in connection with a qualifying activity of the employer. ... In general, the determination will be made by comparing the actual time an individual spent performing qualifying duties (duties performed in connection with a qualifying activity) to the total time the individual spent performing all employment duties during that period. ...

Reasons: The individual is a volunteer and is not remunerated for any services but is reimbursed for the cost of an internet connection. ... The particular individual was reimbursed for the cost of an Internet service connection that was used by him in connection with the volunteer services that he provided to the Institution. ... You have asked whether the reimbursement for the cost of the Internet service connection was required to be reported on Form T1204 by the payer. ...

To qualify for the OETC, an individual must: (a) be employed by a specified employer (generally, a resident of Canada), other than for the performance of services under a prescribed international development assistance program of the Government of Canada: (b) be employed in connection with a contract (or for the purpose of obtaining such a contract) under which the specified employer carried on business outside Canada with respect to the exploration for or exploitation of petroleum, natural gas, minerals or other similar resources, with respect to any construction, installation, agricultural or engineering project or with respect to an activity performed under contract with the United Nations ("qualifying activity"); and (c) have performed all or substantially all the employment duties (done in connection with a contract described in (b) above) outside Canada. ... During a period of absence from a work location outside Canada, an individual may take vacation time, consult with the specified employer in Canada or perform duties of employment in Canada and still remain eligible for the OETC, provided that throughout the qualifying period substantially all of the individual's employment duties (90% or more) are performed outside Canada in connection with a qualifying activity of the employer. ... In general, the determination will be made by comparing the actual time an individual spent performing qualifying duties (duties performed in connection with a qualifying activity) to the total time the individual spent performing all duties during that period. ...

14 March 2007 External T.I. 2007-0227011E5- Education credit- course related to employment Unedited CRA Tags 118.6 Principal Issues: Two questions are posed: (1) Is a course taken in connection with one's job eligible for the education tax credit? ... For years prior to 2004, the former definition of "qualifying educational program" in the Income Tax Act excluded any program taken by a student: (a) during a period for which the student received income from an office or employment, and (b) 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 is eligible for the education tax credit. ...

If the above exemption is not applicable, you are concerned with Revenue Canada's interpretation of the expression "in connection with" as used in such subparagraph. ... That subparagraph does not provide for an exemption from withholding tax where the payment is made in connection with the sale of property or the negotiation of a contract as does subparagraph 212(1)(d)(iii) of the Act. ... The expression "in connection with" would appear to have a broad connotation, however, as indicated in the case of Gene A. ...

Pursuant to Article 21, a Norwegian resident who carries on activities in Canada in connection with the exploration or exploitation of the seabed and subsoil and their natural resources is deemed to be carrying on a business in Canada through a permanent establishment or fixed base situated therein. We note that this provision only requires that the Norwegian resident carry on activities in connection with the exploration and exploitation of the natural resource of Canada, which in our view is a lower threshold than carrying on a business. However, those activities must be in connection with the exploration or exploitation of the seabed and subsoil and their natural resources. ...

Principal Issues: Does the wording of subparagraph 149(1)(o.2)(i) of the Act restrict the activities of a corporation that was incorporated before Nov. 17, 1978 solely in connection with, or for the administration of, a registered pension plan? ... For example, the wording of paragraph 149(1)(o.1) refers to a corporation incorporated and operated solely for the administration of a registered pension plan, whereas, subparagraph 149(1)(o.2)(i) refers to a corporation incorporated solely in connection with a registered pension plan or a corporation incorporated solely for the administration of a registered pension plan. ... However, in our opinion, if the corporation was incorporated in XXXXXXXXXX and was incorporated solely in connection with, or for the administration of, a registered pension plan, the business activities of the corporation would not be restricted for purposes of subparagraph 149(1)(o.2)(i) of the Act. ...

Principal Issues: Are reasonable allowances for the use of a motor vehicle in connection with the duties of an office or employment that are based on a per-kilometer rate for travel outside the metropolitan area and a flat rate for travel inside the metropolitan area taxable benefits? ... The amount based upon a flat rate for travel within the metropolitan area is deemed not to be reasonable by virtue of paragraph 6(1)(b)(x) of the Act since it is not based solely on the number of kilometers for which the vehicle is used in connection with or in the course of the office or employment, and therefore it is a taxable benefit. ... Subparagraph 6(1)(b)(x) of the Act deems an allowance not to be reasonable where the measurement of the use of the vehicle is not based solely on the number of kilometres for which it is used in connection with or in the course of the office or employment. ...

Reasons: The dividend income paid to USco is not derived from Canada in connection with or incidental to the trade or business of USco. 2019 International Fiscal Association Conference CRA Roundtable Question 8 – Active Trade or Business Test under the LOB Clause Paragraph 3 of Article XXIX-A (this Article hereinafter referred to as the “LOB Clause”) of the Canada-U.S. Tax Convention (the “Treaty”) generally provides that a U.S. resident, that is not a qualifying person under paragraph 2 of the LOB Clause and that is engaged in the active conduct of a trade or business in the U.S., can claim Treaty benefits with respect to items of income that are derived from Canada in connection with or incidental to that trade or business, provided a number of other conditions are met. In a situation where a corporation resident in Canada (“Canco”) pays a dividend to its U.S. resident parent corporation (“USco”), would paragraph 3 of the LOB Clause apply in connection with the dividend paid to USco if such income is indirectly derived through the business of Canco’s foreign affiliate (“FA”) that is a resident in a third country? ...