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In particular, paragraph 3 provides that treaty benefits may be available to a US resident with respect to income derived from Canada, provided that the income is derived in connection with, or is incidental to, the active conduct of a trade or business (other than certain investment businesses) carried on in the US by the US resident, or a person related to the US resident, and provided that the US trade or business is substantial in relation to the activity carried on in Canada giving rise to the income. ...

Subsequently, on October 25, 2017 the Department of Finance released revised legislative proposals, followed on October 27 by Bill C-63, which expanded the scope of the tax-deferral mechanism of subsections 87(8.4) and (8.5) to also include joint elections made in connection with dispositions of certain taxable Canadian property (that is not treaty-protected property) that are interests in partnerships and interests in trusts. ...

S. 95(3)(b) concerns services performed in connection with the purchase or the sale of “goods.” ...

In this regard, the Act does not specify whether the "FMV of any consideration … received by the donee for the disposition” of the NQS refers to the specific concept of "proceeds of disposition" provided for in s. 54 or, more generally, to any consideration received in connection with such disposition, including the portion of such consideration that would constitute a deemed dividend under s. 84(3), in the event of a redemption of shares. ... Official Response 7 October 2021 APFF Roundtable Q. 18, 2021-0901091C6- TOSI continuity rule for inherited property Q.19 Ruling service fee remissions The service fees charged by CRA in connection with an advance (including supplementary) income tax ruling (an "Advance Income Tax Ruling") as well as a pre-advance ruling consultation ("Pre-advance Consultation") are governed by the Service Fees Act, s. 7 of which provides for an obligation to refund a portion of the service fees charged ("Remission") when a performance standard is not met a) How will this be done? ...

Darren Weiner provided a verbal update (b) Carbon fuel charge audits Please provide an update regarding CRA audits in connection with the fuel charge under Part 1 of the Greenhouse Gas Pollution Pricing Act. ... Are rapid COVID tests performed by someone who is not a medical practitioner/nurse/pharmacist (e.g., a travel agency without a connection to a medical practitioner, nurse or pharmacist) taxable? ...

We understand that it can be argued that this shift of an amount from the ERDTOH account to the NERDTOH account results from the fact that paragraph 186(1)(b) makes no connection between the type of RDTOH account entitling Aco to the DR and the type of dividend received by Bco and Cco. ... The courts have generally recognized that, in order to conclude that several persons collectively exercise control of a corporation, there must be a sufficient connection between those persons, such as a voting rights agreement, an agreement to act in concert or business or family ties. ...

As you know, the T3 return is an income tax and an information return, and it serves to report not only information with respect to the reporting trust, but also information such as that affecting the taxation of persons, beneficiaries or settlors having some connection to the trust. ...

The lessor has no other relevant connection to Canada, e.g., agents, employees or facilities in Canada, soliciting of Canadian business, Canadian bank accounts or servicing obligations under the lease. ...

Regarding GAAR, CRA would look for a sufficient connection between the deceased person and the property that is being distributed, and the specified individual, to justify or support the application of the deeming rule in these circumstances. ...

Official Response 3 December 2024 CTF Roundtable Q. 13, 2024-1038261C6- Standard Convertible Debentures and Part XIII Tax Q.14- Scope of active business income Corporation A is a Canadian controlled private corporation that carries on active business in Canada, and holds property in connection therewith. ...