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Archived CRA website

ARCHIVED - Income Tax - Technical News No. 41

However, paragraph XXIX A(3) does not apply to income derived in connection with a trade or business in the resident state unless that trade or business is substantial in relation to the activity carried on in the other state. ... Meaning of “in connection with” In determining whether Canadian-source income has been derived by a US resident in connection with an active trade or business in the United States, the CRA will be guided by the commentary set out in the technical explanation to the fifth protocol and the 2006 US model technical explanation. 35 In general terms, we would consider Canadian-source income to be derived “in connection with” a trade or business in the United States if the income is derived from an activity in Canada that is a part of, or is complementary to, the trade or business in the United States. ... Example The following example is intended to illustrate a situation in which Canadian-source dividends and taxable capital gains would be considered to be derived in connection with an active trade or business carried on in the United States by a US-resident corporation (USco). ...
Scraped CRA Website

ARCHIVED - Income Tax Technical News No. 41

However, paragraph XXIX A(3) does not apply to income derived in connection with a trade or business in the resident state unless that trade or business is substantial in relation to the activity carried on in the other state. ... Meaning of “in connection with” In determining whether Canadian-source income has been derived by a US resident in connection with an active trade or business in the United States, the CRA will be guided by the commentary set out in the technical explanation to the fifth protocol and the 2006 US model technical explanation. 35 In general terms, we would consider Canadian-source income to be derived “in connection with” a trade or business in the United States if the income is derived from an activity in Canada that is a part of, or is complementary to, the trade or business in the United States. ... Example The following example is intended to illustrate a situation in which Canadian-source dividends and taxable capital gains would be considered to be derived in connection with an active trade or business carried on in the United States by a US-resident corporation (USco). ...
Archived CRA website

ARCHIVED - Income Tax Technical News No. 41

However, paragraph XXIX A(3) does not apply to income derived in connection with a trade or business in the resident state unless that trade or business is substantial in relation to the activity carried on in the other state. ... Meaning of “in connection with” In determining whether Canadian-source income has been derived by a US resident in connection with an active trade or business in the United States, the CRA will be guided by the commentary set out in the technical explanation to the fifth protocol and the 2006 US model technical explanation. 35 In general terms, we would consider Canadian-source income to be derived “in connection with” a trade or business in the United States if the income is derived from an activity in Canada that is a part of, or is complementary to, the trade or business in the United States. ... Example The following example is intended to illustrate a situation in which Canadian-source dividends and taxable capital gains would be considered to be derived in connection with an active trade or business carried on in the United States by a US-resident corporation (USco). ...
Current CRA website

IC78-18R7 Registered Retirement Income Funds

A minimum amount payment cannot be greater than the value of the property held in connection with the fund (see paragraph 20) immediately before the payment. 6. ... For each subsequent year, the minimum amount is calculated by multiplying the fair market value (FMV) of the property (other than certain types of annuities) held in connection with the fund at the beginning of the year by a prescribed factor. ... The term property held in connection with the fund as used in this circular means the value of property held by the carrier of the fund, and the value of earnings from that property, that are relevant in determining the amount payable to the annuitant under the fund. ...
Current CRA website

Tourism and Hospitality Recovery Program (THRP)

The activities that were stopped account for at least approximately 25% of the eligible revenues earned during the prior reference period from or in connection with the affected qualifying property. ... This means that at least 25% of the eligible revenues earned during the prior reference period from (or in connection with) each affected qualifying property came from the activities that were required to stop. If you have any non-arm’s-length tenants at an affected property, use the eligible revenue they earned from (or in connection with) that property during the prior reference period in your calculation. ...
Current CRA website

Eligibility for past subsidies

The activities that were stopped account for at least approximately 25% of the eligible revenues earned during the prior reference period from or in connection with the affected qualifying property. ... This means that at least 25% of the eligible revenues earned during the prior reference period from (or in connection with) each affected qualifying property came from the activities that were required to stop. If you have any non-arm’s-length tenants at an affected property, use the eligible revenue they earned from (or in connection with) that property during the prior reference period in your calculation. ...
Old website (cra-arc.gc.ca)

Delegation under the

SCHEDULE CHILDREN'S SPECIAL ALLOWANCES ACT Section 5- Recipient of special allowance- Where such a payment is approved in respect of a child, the special allowance shall, in such manner and at such times as are determined by the Minister, be paid to the department, agency or institution that maintains the child or, in the prescribed circumstances, to a foster parent Headquarters Positions Director General, Benefit Programs Directorate Director, Benefit Programs Directorate Manager, Benefit Programs Directorate Program Officer, Benefit Programs Directorate Section 6- Report to be made- Where a special allowance ceases to be payable in respect of a child, the chief executive officer of the department, agency or institution that made the application in respect of the child shall notify the Minister in the prescribed form and manner Headquarters Positions Director General, Benefit Programs Directorate Director, Benefit Programs Directorate Manager, Benefit Programs Directorate Program Officer, Benefit Programs Directorate Field Positions Director, International Tax Services Office Director, Tax Services Office Director, Tax Centre Assistant Director, Individual and Benefit Services Division Assistant Director, Assessment Reviews and Adjustments Division Manager, Individual and Benefit Services Division Manager, Processing Division Manager, Assessment Reviews and Adjustment Division Team Leader, Processing Division Team Leader, Assessment Reviews and Adjustments Division T1 Processing Resource Officer, Processing Division T1 Client Services Resource Officer, Assessment Reviews and Adjustments Division T1 Client Services Officer, Assessment Reviews and Adjustments Division T1 Processing Clerk, Individual and Benefit Services Division T1 Client Services Clerk, Assessment Reviews and Adjustments Division Section 11- Agreements with provinces for exchange of information- The Minister may enter into an agreement with the government of any province for the purpose of obtaining; and exchanging information in connection with the administration and enforcement of this Act Headquarters Positions Director General, Benefit Programs Directorate Director, Benefit Programs Directorate Manager, Benefit Programs Directorate Program Officer, Benefit Programs Directorate Section 12- Administration of oaths- May designate who may administer oaths and receive affidavits Headquarters Positions Director General, Benefit Programs Directorate Director, Benefit Programs Directorate Manager, Benefit Programs Directorate Program Officer, Benefit Programs Directorate Field Positions Director, International Tax Services Office Director, Tax Services Office Director, Tax Centre Date modified: 2015-06-03 ...
Old website (cra-arc.gc.ca)

GST/HST and Electronic Commerce

The connection is made by a modem, which allows the user to send and receive data over a telephone line. ... The predominant purpose of the supply to the consumer is the Internet connection. As in the case of Internet access services, the supply of a connection to the Internet is considered to be a telecommunication service. ...
Current CRA website

GST/HST and Electronic Commerce

The connection is made by a modem, which allows the user to send and receive data over a telephone line. ... The predominant purpose of the supply to the consumer is the Internet connection. As in the case of Internet access services, the supply of a connection to the Internet is considered to be a telecommunication service. ...
Archived CRA website

ARCHIVED - Income Tax - Technical News No. 27

Any comments relating to specific ITs can be sent by email to bulletins@ccra.gc.ca List of Archived Interpretation Bulletins The publications listed below will now be found in the Archived Income Tax Interpretation Bulletins section of the CCRA Web site at the following address: www.ccra.gc.ca/menu/ITSA-e.html IT-111R2, Annuities Purchased from Charitable Organizations IT-150R2, Acquisition From a Non-resident of Certain Property on Death or Mortgage Foreclosure or by Virtue of a Deemed Disposition IT-156R, Feedlot Operators IT-183, Foreign Tax Credit – Member of a Partnership IT-254R2, Fishermen – Employees and seafarers – Value of rations and quarters IT-314, Income of Dealers in Oil and Gas Leases IT-316, Awards for Employees' Suggestions and Inventions IT-317R, Capital Cost Allowance – Radio and Television Equipment IT-319, Cost of Obligations Owned on December 31, 1971 IT-321R, Insurance Agents and Brokers – Unearned Commissions IT-323, Sale of Mortgage Included in Proceeds of Disposition of Depreciable Property IT-338, Partnership Interests – Effects on Adjusted Cost Base Resulting from the Admission or Retirement of a Partner IT-370, Trusts – Capital Property Owned on December 31, 1971 IT-374, Meaning of "Settlor" IT-388, Income Bonds Issued by Foreign Corporations IT-392, Meaning of the term "share" IT-409, Winding-up of a non-profit organization IT-446R, Legacies IT-449R, Meaning of "Vested Indefeasibly" IT-452, Utility Service Connections IT-461, Forfeited Deposits IT-483, Credit Unions IT-488R2, Winding-up of 90% Owned Taxable Canadian Corporations IT-493, Agency Cooperative Corporations Income Tax Publications Subscriber List The CCRA is introducing a new electronic mailing list to advise our subscribers of all new income tax related technical publications (ITs, TNs, ICs), as well as other matters of interest to tax professionals and taxpayers. ...

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