Search - connection

Results 1041 - 1050 of 1132 for connection

Jack Bernstein, Francesco Gucciardo, "Update on Canada-U.S. Merges and Acquisitions", Tax Notes International, March 16, 2015, p. 993. -- summary under Paragraph 20(1)(c)

Structured properly, the shares issued by the Canadian acquisition company in connection with the share subscription by LLC under the forward subscription agreement (using the funds paid by the Canadian acquisition company on account of the interest on the loan) should be treated as a tax-free stock dividend for U.S. federal income tax purposes. ...

H. Michael Dolson, "Trust Residence After Garron: Provincial Considerations", Canadian Tax Journal, (2014) 62:3, 671-99. -- summary under Subsection 2601(1)

One must caution, however, that this will require the decision making in connection with the trust property to be taken in a more formal manner than might otherwise be the case. ...

David Bunn, Mark Dumalski, "Proposed Amendments to Subsection 85.1(4)", International Tax Highlights, Vol. 1, No. 2 November 2022, p. 6 -- summary under Subsection 85.1(4)

For two events to be part of the same series, one needs to be undertaken “because of” or “in relation to” the other, and the connection between the events needs to be closer than an extreme degree of remoteness or a mere possibility (OSFC Holdings and Copthorne). ...

Angelo Discepola, Robert Nearing, "A Reply to the CRA's Classification of Florida and Delaware LLLPs and LLPs as Corporations", 2016 Conference Report (Canadian Tax Foundation), 24:1-39 -- summary under Section 96

[T]he wording in partial-shield jurisdictions departs somewhat from the full-shield language contained in section 15-306(c) of DRUPA by specifically stating that the liability shield severs the link between the partner and the partnership only with respect to obligations of the partnership arising in connection with negligent acts…. ... In other words, it should not be assumed that a general partner of an LLLP is shielded from all possible claims arising in connection with the management of an LLLP. ...

Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Taxation of Beneficiaries Resident in Canada", Chapter 4 of Canadian Taxation of Trusts (Canadian Tax Foundation), 2016. -- summary under Subsection 106(2)

This conclusion by the CRA appears to be incorrect because it assumes that paragraph 106(2)(a) can apply to a disposition of an income interest, even though no one acquires the interest and the disposition occurs in connection with the termination of the trust…. ...

Jeffrey T. Love, Kenneth R. Hauser, "How Various Aggregation Rules Apply to Trusts", 2018 Conference Report (Canadian Tax Foundation), 28: 1-79 -- summary under Subparagraph 251(2)(c)(i)

The trust company acts as trustee of a trust governed by an RRSP whose annuitant has no other connection to the bank group. ...

Gwendolyn Watson, "The Foreign Affiliate Surplus Reclassification Rule", Canadian Tax Journal (Canadian Tax Foundation) (2019) 67:4, 1233-66 -- summary under Subsection 5907(2.02)

These cases considered the issue in the context of property that ceased to exist under the doctrine of merger in connection with the transfer. ...

GST/HST Memorandum 20-6 “Tutoring and Equivalent Services” December 2019 -- summary under Section 11

Requirement for direct connection between instruction and school credit, or curriculum-designed, course 9. ... In order for the exemption to apply, it must be evident that there is some direct connection between the supply of the service of tutoring or instructing in question and the course approved for credit by, or the curriculum designated by, a school authority. ...

June 2012 Draft GST/HST Technical Information Bulletin B-103, "Harmonized Sales Tax - place of supply rules for determining whether a supply is made in a province" -- summary under Subsection 13(1)

June 2012 Draft GST/HST Technical Information Bulletin B-103, "Harmonized Sales Tax- place of supply rules for determining whether a supply is made in a province"-- summary under Subsection 13(1) Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 13- Subsection 13(1) Includes: Example 92 (the BC office of a corporation which receives the advice and had meetings with the advisor has a closer connection than the head office in Ontario which contracted with the advisor and the Alberta accounting office to which the invoice was directed to be sent); Example 95 (head office with which the consultant entered into a "global framework" agreement does not have as close a connection as the regional office determining the specific service which it requires and issues a purchase order); and Example 96 (the business address of a mutual fund trust in Ontario has a closer connection the the services of an accounting firm than the address of the fund sponsor or of the trustee). ...

GST/HST Memorandum 3-3-5 “Place of Supply in a Province – General Rules for Intangible Personal Property” January 2025 -- summary under Clause 6(2)(b)(i)(A)

An address of the recipient obtained by a supplier is only relevant [as a business address] if it is obtained in the ordinary course of the supplier's business practices in connection with the supply. ... An address of the recipient obtained by a supplier in the ordinary course of business could therefore include any of the following: an address of the recipient from which the supplier is hired in connection with a supply pursuant to an agreement for the supply (the contracting address) an address of the recipient that the supplier deals with in connection with a supply a billing address of the recipient in connection with a supply Example 8 A student in Ontario with a New Brunswick permanent address purchases for $250 at an Ontario membership desk a six-month membership to use the club’s fitness facilities, which are in both provinces. ...

You are here