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According to subsection 147.5(2) of the ITA, the Minister of National Revenue will not accept a pooled pension plan for registration unless, in his or her opinion, the plan complies with the following conditions: The main purpose of the plan is to accept and invest contributions in order to provide retirement income to plan members, subject to the limits and other requirements of the ITA; One account is kept for each member under the member’s SIN: to which are credited all contributions made to the plan for the member, and any earnings of the plan allocated to the member; and to which are charged all payments and distributions made for the member; The only benefits provided under the plan for each member are benefits determined only with reference to, and provided by, the amount in the member’s account; All earnings of the plan are allocated to plan members on a reasonable basis and no less than once a year; An arrangement under which property is held in connection with the plan is acceptable to the Minister of National Revenue. ... A PRPP becomes a revocable plan at any time that: a contribution is made to the plan other than an amount: paid by a member of the plan; paid by the employer or former employer of a member of the plan in respect of the member; or transferred to the plan in accordance with any of subsections 147.5(21), 146(16) and (21), 146.3(14) and (14.1), 147(19) and 147.3(1), and (4) to (7) of the ITA; a contribution is made to the plan in respect of a member after the calendar year in which the member attains 71 years of age, other than a permissible transfer described above; a participating employer makes contributions to the plan in a calendar year in respect of a member of the plan in excess of the RRSP dollar limit for the year, except in accordance with a direction by the member; a distribution is made from the plan other than: a payment of benefits in accordance with subsection 147.5(5) of the ITA, or a return of contributions: if a contribution has been made as the result of a reasonable error by the member or participating employer and the return of contributions is made to the contributor no later than December 31 of the year following the calendar year in which the contribution was made; to avoid revocation of the registration of the plan; to reduce the amount of tax that would otherwise be payable, under Part X.1 by a member; or to comply with any requirement under the ITA; property is held in connection with the plan that: the administrator knew or ought to have known was a restricted investment for the plan; or in the case of a designated pooled pension plan, is a share or a debt of, or an interest in, a participating employer of the plan or any person or partnership that does not deal at arm’s length with a participating employer, or an interest (or for civil law, a right) in, or a right to acquire, such a share, debt or interest; (see ¶ 21.) the value of a member’s rights under the plan depends on the value of, or income or capital gains in respect of, property that would be described in paragraph 147.5(3)(e) of the ITA if it were held in connection with the plan; the administrator borrows money or other property for the purposes of the plan; or the plan or administrator does not comply with a prescribed condition. ... A designated pooled pension plan, for a calendar year, is defined in subsection 147.5(1) of the ITA as a pooled pension plan if, at any time in the year (other than the year in which the plan became registered as a PRPP), it meets any of the following conditions: the plan has fewer than 10 participating employers; the fair market value of property held in connection with the accounts of all members of the plan employed by a particular employer is more than 50% of the fair market value of the property held in connection with the plan; more than 50% of the members are employed by a particular participating employer; or it is reasonable to conclude that the participation in the plan of one or more participating employers occurs mainly to avoid the application of a, b, or c. ...

According to subsection 147.5(2) of the ITA, the Minister of National Revenue will not accept a pooled pension plan for registration unless, in his or her opinion, the plan complies with the following conditions: The main purpose of the plan is to accept and invest contributions in order to provide retirement income to plan members, subject to the limits and other requirements of the ITA; One account is kept for each member under the member’s SIN: to which are credited all contributions made to the plan for the member, and any earnings of the plan allocated to the member; and to which are charged all payments and distributions made for the member; The only benefits provided under the plan for each member are benefits determined only with reference to, and provided by, the amount in the member’s account; All earnings of the plan are allocated to plan members on a reasonable basis and no less than once a year; An arrangement under which property is held in connection with the plan is acceptable to the Minister of National Revenue. ... A PRPP becomes a revocable plan at any time that: a contribution is made to the plan other than an amount: paid by a member of the plan; paid by the employer or former employer of a member of the plan in respect of the member; or transferred to the plan in accordance with any of subsections 147.5(21), 146(16) and (21), 146.3(14) and (14.1), 147(19) and 147.3(1), (4) and (5) to (7) of the ITA; a contribution is made to the plan in respect of a member after the calendar year in which the member attains 71 years of age, other than a permissible transfer described above; a participating employer makes contributions to the plan in a calendar year in respect of a member of the plan in excess of the RRSP dollar limit for the year, except in accordance with a direction by the member; a distribution is made from the plan other than: a payment of benefits in accordance with subsection 147.5(5) of the ITA, or a return of contributions: if a contribution has been made as the result of a reasonable error by the member or participating employer and the return of contributions is made to the contributor no later than December 31 of the year following the calendar year in which the contribution was made; to avoid revocation of the registration of the plan; to reduce the amount of tax that would otherwise be payable, under Part X.1 by a member; or to comply with any requirement under the ITA; property is held in connection with the plan that: the administrator knew or ought to have known was a restricted investment for the plan; or in the case of a designated pooled pension plan, is a share or a debt of, or an interest in, a participating employer of the plan or any person or partnership that does not deal at arm’s length with a participating employer, or an interest (or for civil law, a right) in, or a right to acquire, such a share, debt or interest; (see ¶ 21.) the value of a member’s rights under the plan depends on the value of, or income or capital gains in respect of, property that would be described in paragraph 147.5(3)(e) of the ITA if it were held in connection with the plan; the administrator borrows money or other property for the purposes of the plan; or the plan or administrator does not comply with a prescribed condition. ... A designated pooled pension plan, for a calendar year, is defined in subsection 147.5(1) of the ITA as a pooled pension plan if, at any time in the year (other than the year in which the plan became registered as a PRPP), it meets any of the following conditions: the plan has fewer than 10 participating employers; the fair market value of property held in connection with the accounts of all members of the plan employed by a particular employer is more than 50% of the fair market value of the property held in connection with the plan; more than 50% of the members are employed by a particular participating employer; or it is reasonable to conclude that the participation in the plan of one or more participating employers occurs mainly to avoid the application of a, b, or c. ...

According to subsection 147.5(2) of the ITA, the Minister of National Revenue will not accept a pooled pension plan for registration unless, in his or her opinion, the plan complies with the following conditions: The main purpose of the plan is to accept and invest contributions in order to provide retirement income to plan members, subject to the limits and other requirements of the ITA; One account is kept for each member under the member’s SIN: to which are credited all contributions made to the plan for the member, and any earnings of the plan allocated to the member; and to which are charged all payments and distributions made for the member; The only benefits provided under the plan for each member are benefits determined only with reference to, and provided by, the amount in the member’s account; All earnings of the plan are allocated to plan members on a reasonable basis and no less than once a year; An arrangement under which property is held in connection with the plan is acceptable to the Minister of National Revenue. ... A PRPP becomes a revocable plan at any time that: a contribution is made to the plan other than an amount: paid by a member of the plan; paid by the employer or former employer of a member of the plan in respect of the member; or transferred to the plan in accordance with any of subsections 147.5(21), 146(16) and (21), 146.3(14) and (14.1), 147(19) and 147.3(1), (4) and (5) to (7) of the ITA; a contribution is made to the plan in respect of a member after the calendar year in which the member attains 71 years of age, other than a permissible transfer described above; a participating employer makes contributions to the plan in a calendar year in respect of a member of the plan in excess of the RRSP dollar limit for the year, except in accordance with a direction by the member; a distribution is made from the plan other than: a payment of benefits in accordance with subsection 147.5(5) of the ITA, or a return of contributions: if a contribution has been made as the result of a reasonable error by the member or participating employer and the return of contributions is made to the contributor no later than December 31 of the year following the calendar year in which the contribution was made; to avoid revocation of the registration of the plan; to reduce the amount of tax that would otherwise be payable, under Part X.1 by a member; or to comply with any requirement under the ITA; property is held in connection with the plan that: the administrator knew or ought to have known was a restricted investment for the plan; or in the case of a designated pooled pension plan, is a share or a debt of, or an interest in, a participating employer of the plan or any person or partnership that does not deal at arm’s length with a participating employer, or an interest (or for civil law, a right) in, or a right to acquire, such a share, debt or interest; (see ¶ 21.) the value of a member’s rights under the plan depends on the value of, or income or capital gains in respect of, property that would be described in paragraph 147.5(3)(e) of the ITA if it were held in connection with the plan; the administrator borrows money or other property for the purposes of the plan; or the plan or administrator does not comply with a prescribed condition. ... A designated pooled pension plan, for a calendar year, is defined in subsection 147.5(1) of the ITA as a pooled pension plan if, at any time in the year (other than the year in which the plan became registered as a PRPP), it meets any of the following conditions: the plan has fewer than 10 participating employers; the fair market value of property held in connection with the accounts of all members of the plan employed by a particular employer is more than 50% of the fair market value of the property held in connection with the plan; more than 50% of the members are employed by a particular participating employer; or it is reasonable to conclude that the participation in the plan of one or more participating employers occurs mainly to avoid the application of a, b, or c. ...

. ¶3.82 has been revised to delete previous wording that may have suggested that the deduction under paragraph 110(1)(g) is limited to tuition assistance that is received in connection with adult basic education. ¶3.82.1 has been added to provide examples of the types of training assistance to which the deduction under paragraph 110(1)(g) may apply. ... However, these sections now appear in the Table of contents for easy access; the statement that folios are only available in electronic format has been moved to the end of the Application section; and the words “as promulgated under the Act” in connection with the Income Tax Regulations have been removed from the Application section, in the interest of using plain language. ... This amendment was made by 2007, c. 2, s. 6(3), effective for the 2006 and subsequent tax years, to increase the $3,000 exemption to an unlimited exemption where scholarship income was received in connection with an educational program that qualified under subsection 118.6(2). ¶3.91 (formerly included in ¶43 of IT-75R4) has been revised to reflect the amendment to paragraph 56(3)(a) to effectively extend (i) to the preceding and following years. ...

This bulletin also discusses other topics in connection with eligible capital property, including the transition from the old system to the new system. ... Where subsection 14(3) applies, the transferee's EC expenditure is "deemed" (determined) to be 4/3 of (a) the amount determined by the transferor as the EC amount from the disposition of the property minus (b) the total of all amounts that may reasonably be considered to have been claimed as a section 110.6 capital gains deduction by the transferor or any other person with whom the transferee was not dealing at arm's length in connection with the transferor's disposition of the property to the transferee or in connection with any previous disposition of the same property. ... In this connection, see the transitional rules described in ¶s 28 and 29 above. ...

This bulletin also discusses other topics in connection with eligible capital property, including the transition from the old system to the new system. ... Where subsection 14(3) applies, the transferee's EC expenditure is "deemed" (determined) to be 4/3 of (a) the amount determined by the transferor as the EC amount from the disposition of the property minus (b) the total of all amounts that may reasonably be considered to have been claimed as a section 110.6 capital gains deduction by the transferor or any other person with whom the transferee was not dealing at arm's length in connection with the transferor's disposition of the property to the transferee or in connection with any previous disposition of the same property. ... In this connection, see the transitional rules described in ¶s 28 and 29 above. ...

This bulletin also discusses other topics in connection with eligible capital property, including the transition from the old system to the new system. ... Where subsection 14(3) applies, the transferee's EC expenditure is "deemed" (determined) to be 4/3 of (a) the amount determined by the transferor as the EC amount from the disposition of the property minus (b) the total of all amounts that may reasonably be considered to have been claimed as a section 110.6 capital gains deduction by the transferor or any other person with whom the transferee was not dealing at arm's length in connection with the transferor's disposition of the property to the transferee or in connection with any previous disposition of the same property. ... In this connection, see the transitional rules described in ¶s 28 and 29 above. ...

However, there must be a direct connection between the supplies acquired and the activities engaged in by the person. ... Under subparagraph 6(1)(b)(v), (vi), (vii) or (vii.1) of the ITA, the following allowances are excluded from an income from office or employment: reasonable allowances for travel expenses received by an employee from the employer in connection with the selling of property or negotiating of contracts for the employee’s employer; reasonable allowances received by a minister or clergyman in charge of or ministering to a diocese, parish or congregation for expenses for transportation incident to the discharge of the duties of that office or employment; reasonable allowances for travel expenses (other than allowances for the use of a motor vehicle) received by an employee (other than an employee employed in connection with the selling of property or the negotiating of contracts for the employer) from the employer for travelling away from the municipality where the employer’s establishment at which the employee ordinarily worked or to which the employee ordinarily reported was located, and the metropolitan area, if there is one, where that establishment was located, in the performance of the duties of the employee’s office or employment; and reasonable allowances for the use of a motor vehicle received by an employee (other than an employee employed in connection with the selling of property or the negotiating of contracts for the employer) from the employer for travelling in the performance of the duties of the office or employment. ... Under subparagraphs 6(1)(b)(x) and (xi) of the ITA, an allowance paid to an employee for the use of a motor vehicle in connection with the activities of the employer is considered to be reasonable only if the following conditions apply: the allowance is based only on the number of kilometres driven in a year in connection with, or in the course of, an office or employment; the rate per kilometre is reasonable; and the employee is not reimbursed for expenses related to the same use of the motor vehicle, other than a reimbursement for supplemental business insurance, toll or ferry charges, not already included in the allowance. ...

The Directorate will not provide any written comments in connection with a Pre-ruling Consultation. ... This consent will also apply to a supplemental ruling issued in connection with the initial Ruling. ... In making this request, we acknowledge and confirm our acceptance of the following terms: A Pre-ruling Consultation will only be considered in connection with a proposed transaction. ...

If for example, expenses are paid by a parent company on behalf of its subsidiary, in connection with the issuance of shares by its subsidiary, they are not deductible by the parent company under paragraph 20(1)(e). ... For expenses to qualify under paragraph 20(1)(e), in connection with the issuance or sale of shares, it is not necessary for the taxpayer to obtain additional capital by the issuance or sale of shares. ... When a corporation, partnership, or syndicate enters into a transaction described in ¶ 2(a), the expenses listed below would be deductible under subparagraph 20(1)(e)(i) in computing income for the year in which they are incurred: (a) legal fees in connection with the preparation and approval of a prospectus pertinent to the issuance or sale of shares, units, or interests; (b) accounting or auditing fees in connection with the preparation of reports on financial statements and statistical data for inclusion in, or for presentation with, the prospectus; (c) the cost of printing the prospectus, new share, unit, or interest certificates, etc; (d) registrars' or transfer agents' fees; and (e) filing fees charged by any public regulatory body which requires the filing of a prospectus for acceptance. ¶ 17. ...