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Administrative Policy summary

GST/HST Notice No. 324, "Mining Assets in respect of Cryptoassets" June 2025 -- summary under Subsection 188.2(2)

GST/HST Notice No. 324, "Mining Assets in respect of Cryptoassets" June 2025-- summary under Subsection 188.2(2) Summary Under Tax Topics- Excise Tax Act- Section 188.2- Subsection 188.2(2) Denial of ITCs by virtue of ss. 188.2(2) and (3) (under “Eligibility for ITCs”) Subject to the exclusion in subsection 188.2(5), to the extent that a person acquires, imports or brings into a participating province property or a service for consumption, use, or supply in the course of, or in connection with, mining activities of the person, the person is deemed to have acquired, imported or brought into the participating province, as the case may be, the property or service for consumption, use, or supply otherwise than in the course of commercial activities of the person. ... In addition, if a person at any time consumes, uses, or supplies property or a service in the course of, or in connection with, mining activities of the person, that consumption, use, or supply is deemed to be otherwise than in the course of commercial activities of the person in accordance with subsection 188.2(3). ...
Administrative Policy summary

92 C.R. - Q.51 -- summary under Subsection 49(1)

.- Q.51-- summary under Subsection 49(1) Summary Under Tax Topics- Income Tax Act- Section 49- Subsection 49(1) Warrants issued in connection with a "poison pill" arrangement are a form of option and, therefore, are subject to the usual option rules. ...
Administrative Policy summary

87 C.R. - Q.14 -- summary under Compensation Payments

.- Q.14-- summary under Compensation Payments Summary Under Tax Topics- Income Tax Act- Section 9- Compensation Payments A lease inducement payment received by a firm in connection with its only business location generally will not be included in income. ...
Administrative Policy summary

88 C.R. - "Confidentiality of Taxpayer Information" - "Section 241 of the Income Tax Act" -- summary under Paragraph 241(4)(b)

.- "Confidentiality of Taxpayer Information"- "Section 241 of the Income Tax Act"-- summary under Paragraph 241(4)(b) Summary Under Tax Topics- Income Tax Act- Section 241- Subsection 241(4)- Paragraph 241(4)(b) The amendment would deal with the situation where information provided by a company in connection with a flow-through share issue reveals that a number of expenses allocated to investors do not meet statutory requirements. ...
Administrative Policy summary

February 1995 Manitoba Institute/Bar Round Table, Q. 1 -- summary under Section 61.2

February 1995 Manitoba Institute/Bar Round Table, Q. 1-- summary under Section 61.2 Summary Under Tax Topics- Income Tax Act- Section 61.2 A deduction may be claimed under s. 61.2 in the terminal return of the deceased, and no amount in connection with any claim under s. 61.2 will be added in computing the income of the estate or heirs of the deceased. ...
Administrative Policy summary

1996 Ontario Tax Conference Round Table, Q. 3 (No. 9630040) -- summary under Article 12

Convention, and it is a question of fact whether an arrangement is "in connection with a rental... agreement". ...
Administrative Policy summary

88 C.R. - Q.53 -- summary under Section 62

.- Q.53-- summary under Section 62 Summary Under Tax Topics- Income Tax Act- Section 62 A taxpayer receiving a moving allowance in connection with a temporary move to the United States will not be allowed to deduct moving expenses, notwithstanding his retention of Canadian residency. ...
Administrative Policy summary

90 C.R. - Q6 -- summary under Retirement Compensation Arrangement

.- Q6-- summary under Retirement Compensation Arrangement Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Retirement Compensation Arrangement There is no retirement compensation arrangement where a major shareholder provides a personal guarantee to an employee in connection with certain retirement benefits to be provided by the corporation. ...
Administrative Policy summary

Income Tax Technical News, No. 1, 22 July 1994 -- summary under Timing

Income Tax Technical News, No. 1, 22 July 1994-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 9- Timing Beginning July 1995, sales commission expenses incurred by limited partnerships in connection with the distribution of mutual funds must be amortized on a straight-line basis over three years. ...
Administrative Policy summary

IT-143R3 "Meaning of Eligible Capital Expenditure" -- summary under Legal and other Professional Fees

IT-143R3 "Meaning of Eligible Capital Expenditure"-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees Discussion of legal fees incurred in connection with reorganizations (para. 13), share acquisitions (para. 23). ...

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