Search - connection

However, the CRA Guidance provides that where a holder of a pre-existing individual account opens a new account with the same financial institution, there is no need to re-document the account so long as the due diligence requirements have been or are in the process of being carried out and, where a threshold has been applied in connection with the pre-existing account, the financial institution's computerized systems are able to link the new account to the pre-existing account. ...

If the trust had required the unanimous consent of the trustees and the trustees had no other connection, it is unclear whether the court would have come to the same conclusion. ...

Finance should consider limiting paragraph (b) of the definition so that it carves out only those borrowings in connection with which financial assistance is provided by any source individuals who have attained the age of 24 before the year. ...

A statutory precondition to the establishment of a TFSA (ITA paragraph l46.2(2)(e)) is that at the customer's direction the financial institution "shall transfer all or any part of the property held in connection with the arrangement (or an amount equal to its value) to another TFSA of the holder," a right that assumes that the customer retains title to the property.... ...

Given the nature and extent of his connections to both countries, the court could not conclude that a single country was the center of his vital interests. ...

.'s ("Google") appeal, which contended that an interlocutory injunction that prohibited it from including specific websites in results delivered by its search engines should not have been granted because…[t]he application lacked sufficient connection to BC [and other grounds]… Factual background to suit (p. 13) [E]quustek successfully sued their former distributors for unlawful appropriation of trade secrets….Equustek obtained injunctions against the distributors, prohibiting them from carrying on any business online. ...

When the licensor under an incoming royalty arrangement deals at arm's length with the taxpayer, the connection test will be satisfied only if one of the main purposes of this arrangement is to reduce or avoid withholding tax, or to avoid the back-to-back royalty rules. ...

Sabrina Wong, "Bill C-29 Amendments to the Back-to-Back Rules", International Tax, Wolters Kluwer CCH, December 2016, No. 91, p. 5-- summary under Paragraph 212(3.6)(a) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(3.6)- Paragraph 212(3.6)(a) Potential application to common shares (p. 10) [T]he Character Substitution Rules…generally apply where a "relevant funder" has an obligation to pay a dividend on its shares (other than "specified shares") or an amount under a rent or royalty arrangement, and either the amount of the payment is determined by reference to an amount of interest paid under a "relevant funding arrangement", or there is a causal connection (similar to that under the BTB Loan Rules) between the shares or rent or royalty arrangement and the "relevant funding arrangement". ...

In order to rely on the exemption from withholding tax under the Canada-US treaty [fn 61: … at article XII(3)(b)] the Canadian requests a representation from the licensor that there is no licensing arrangement that may be caught by the connection test in the back-to-back rules. ...

If the trust had required the unanimous consent of the trustees and the trustees had no other connection, it is unclear whether the court would have come to the same conclusion. ...