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Commentary

General - Commentary

In one case, the provision of an interest-free loan in connection with an employee relocation also did not give rise to a benefit (Siwik). ...
Commentary

Paragraph 212.3(18)(c) - Commentary

., an exchange by the CRIC of all the shares of a particular class of shares of the other corporation for shares of another class in connection with a change in the articles or other corporate charter of the other corporation. ...
Commentary

Paragraph 8(1)(c) - Commentary

Under s. 8(1)(c)(iv), where the taxpayer's principal place of residence or other principal living accommodations which is ordinarily occupied by the taxpayer in the year is owned or rented by the clergy person, the deduction is equal to the least of three amounts: the employee's remuneration for the year from the office or employment; the greater of: (a) 1 /3 of the employee's total remuneration from the employment for the year; and (b) $1,000 per month (to a maximum of ten months) in the year during which the employee meets the conditions set out in subparagraphs 8(1)(c)(i) and (ii); and the rent paid or the fair rental value of the residence including utilities (this amount must be reduced by the total of all other amounts deducted in computing the employee 's income from a business or from an office or employment in connection with the same accommodation). ...
Commentary

Subsection 212.3(9) - Commentary

., an investment described in paragraph 212.3(10)(b)), dividends or reductions of PUC in respect of the class or series of shares of the subject corporation (or the portion of a reduction of PUC or a dividend in respect of substituted shares that "can reasonably be considered to relate to the subject shares"), or repayments of or proceeds from the disposition of debt obligations, or other amounts owing by the subject corporation, in connection with an investment described in ss. 212.3(10)(c), (d) or (e)(i). ... In connection with a public offering by a listed non-resident company (FA), CRIC subscribes $100 for 100 units of FA, with each unit consisting of one common share and a warrant to acquire a further common share at a subscription price of $1 – with CRIC thereby acquiring 15% of the common shares of FA. $80 of this amount is reasonably allocated to the common shares, and $20 to the warrants. ...
Commentary

Subsection 212.3(7) - Commentary

There is an exclusion for contributed surplus which arose "in connection with" an investment to which s. 212.3(2) applied. ...

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