Search - connection

They import such meanings '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. ... There is no requirement that the revenue guarantee have any connection with either the production of the video or the ownership of the video.   ...

They import such meanings `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. ... There is no requirement that the revenue guarantee have any connection with either the production of the video or the ownership of the video. ...

Secondly, the recent amendments to Subsection 6(2) of the Act, which defines the "reasonable standby charge", now restricts the entitlement to a reduced standby charge to those employees whose use of the automobile, as measured in kilometres driven, in connection with the duties of his employment is at least 90%. In this regard, the wording of subsection 6(6) of the Act does not support your assumption that the kilometres driven between the principal residence and the specia1 work site would be considered as kilometres driven in connection with the duties of employment. Consequently, in each of the examples provided by you the distance travelled in connection with the duties of employment would be limited to 10,000 kilometres, well under the 90% of total kilometres needed to become entitled to a reduced standby charge. ...

All contributions made under the EBP after the establishment of the Statutory Arrangement and all property that can reasonably be considered to derive from those contributions are deemed to be property held in connection with the Statutory Arrangement and not in connection with the Existing Arrangement. Therefore, income from the property (including a deferred annuity) in connection with the Existing Arrangement will be subject to the provisions of the Act dealing with an EBP. ... On the other hand, income from the property (including a deferred annuity) in connection with the Statutory Arrangement will be subject to the new RCA provisions of the Act. ...

You advised during a subsequent telephone conversation XXX Dodd) that the employee benefit plan texts were merely supplied for purposes of general information in connection with certain registration matters. You confirmed that as such, no comment from this office was required in connection with these plans and accordingly, we are closing our file. ...

Income Tax Convention exempts such payments made to a U.S. resident from Canada tax except where the information is provided in connection with a rental or franchise agreement. ... (b)Would a licence of information concerning industrial, commercial or scientific experience combined with a licence of computer software for use in dealing with the information be considered to be "in connection with a rental agreement"? ... (b) Again, it is a question of fact whether or not such an arrangement would be considered to be "in connection with a rental...agreement". ...

One test is that the individual perform all or substantially all the duties of his employment outside Canada "... in connection with a contract under which the specified employer carried on business outside Canada with respect to... ... The expressions "in connection with" and "with respect to" are considered to have very broad meanings. ... Department's Position Non-operating support personnel, who otherwise meet the criteria set out in section 122.3 of the Act and who were employed by a specified employer in connection with a contract under which the specified employer carried on a business outside Canada in a qualified activity, will be eligible to claim the OETC. ...

Position TAKEN: The marketing fees would be exempt from the 25% withholding tax to the extent that such fees are made for services performed by the taxpayer in connection with the sale of crude oil or the negotiation of a contract for the taxpayer. ... Rooke Section A/Assistant Director of Audit Peter Lee (613) 957-8977 Attention: Susan Clozza International Audit 943366 XXXXXXXXXX Further to our recent telephone conversation (Lee/Clozza), this is in reply to your memorandum of December 15, 1994 and to confirm that we are not able to comment on the reasonableness of the marketing fees paid by XXXXXXXXXX and on whether such fees were made exclusively for services performed in connection with the sale of crude oil and the negotiation of crude oil sales contracts. ... Accordingly, it is our view that the marketing fees would be exempt from the 25% withholding tax under subparagraph 212(1)(d)(iii) of the Act to the extent that such fees are made for services performed by XXXXXXXXXX in connection with the sale of crude oil or the negotiation of a contract for XXXXXXXXXX. ...

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. ... Accordingly, in our view, the award is paid by an employer in connection with an employee's office or employment and should be included in the employee's income under paragraph 6(1)(a) of the Act. ...

The technical issue arises in connection with the attempted filing by the taxpayer of a waiver in respect of his 1985 income tax return.  ... In connection with the technical issue, we have been advised by the Department of Finance, Tax Policy and Legislation Branch, that the reference point in paragraph 152(4)(a) from which the waiver filing deadline is determined, is intended to be the date of issuance of either the original assessment or the original notification. ... In connection with the question of whether we would accept a late-filed election under subsection 110.4(2), we consulted with Assessing and Enquiries Directorate who advised us that even if the waiver in question was valid and    1985 return was open, it is not the Department's policy to accept requests to file a late-filed election pursuant to subsection 110.4(2) of the Act.  ...