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In our view, this definition aims to ensure there is no connection between the transfer, and the person or partnership that already has an interest in the non-resident trust, or would have such an interest in the future. ... Preliminary response Our connection was interrupted for part of this answer, which expanded slightly on CRA’s answer to IFA 2021 Q.9. ...

., 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? ... Moreover, Country A accounting standards do not require any restatement of CFA’s original financial statements with respect to the relevant taxation years in connection with the adjustment to CFA’s income under Country A’s tax law. ...

., the LOB) reads in part "the benefits of this [Treaty] shall apply to that resident person [US Parent] with respect to income derived from [Canada] in connection with or incidental to that trade or business (including any such income derived directly by that resident person through one or more other persons that are residents of [Canada]…" Assume that US Parent is carrying on a business that is upstream, downstream or parallel to the business carried on by Can Sub. ... Notes From Presentation This situation is similar to Q.4 of ITTN No. 41 (i.e., the value of the US Holdco shares- and thus the taxable capital gain- is derived from an active business in Canada that is parallel to the active business carried on by US Parent in the United States, so that such gain is derived in connection with US Parent’s active business.) ...

It should be attached to one of the existing forms that are already required in connection with a flow-through share offering, such as the T100A. ... In many cases, this equipment is housed and operated in large datacenters capable of providing significant electricity and internet connections required for their use. ... Although crypto-asset mining equipment can connect directly to a blockchain network through an internet connection, most will prefer to connect to “mining pool” servers to increase their likelihood of receiving rewards. ...

Summary of suggested answer S. 7 should be applicable as the services are not “in respect” of the parts and the only connection with Canada is doing the processing here. ... In particular, it appears that based on the application of GST/HST Policy Statement P-169R there would be a direct connection between the services and the parts. ... The acquisition entity may be denied ITCs in connection with GST/HST it has incurred if it is not registered on a timely basis, which could have HST implications. ...

When applied to ss. 7 and 247(2), this passage indicates that there is no direct connection – whether the amount is deductible is one matter, and the role the stock-based compensation plays in the application of s. 247(2), is a separate matter. ... The loan is incurred in connection with US LLC 2’s real estate operations in Canada, which constitutes its permanent establishment in Canada. ...

It really put blood into the veins of the connections between the authorities, and I think our day-to-day dynamic has improved. ...

CRA preliminary response The short-cut method (or direct assessment method) is an administrative measure adopted by the CRA to permit direct assessments of the shareholders of a corporation who were paid an excess amount in connection with an election under subsection 83(2). ... A, in connection with the estate freeze carried out by Mr. A. in favour of Initial Trust, if the Purpose Test were satisfied. ... Thus, subsection 74.4(2) could apply to the transfer of property made by Initial Trust, in connection with the estate freeze made by it in favour of New Trust, if the Purpose Test was satisfied. ...

Preliminary response B A strong connection between the Gagliese Productions case and a mortgage-lending business is not apparent. It is also unclear what the connection is between the mortgage-lending business and the rentals. ... It serves to report information about the trust itself, but also information that affects the taxation of persons who happen to have some connection to the trust – beneficiaries, settlors, and contributors. ...

Official Response 26 November 2013 CTF Round Table, Q. 5, 2013-0507961C6 Q5(b) – Article XXIX-A of the Canada-US treaty – Active trade or business test Paragraph 3 contains the “active trade or business test”, which if met, entitles certain non-qualifying persons to treaty benefits in respect of income derived from the other contracting state in connection with or incidental to that trade or business. ...