Search - connection

However, for the purposes of the HBP, we consider that a person has entered into an agreement in writing provided that there is a series of correspondence or written documents that constitute, in their entirety, the offer made by an individual and its acceptance by another in connection with the acquisition. ... Depending on the circumstances, various correspondence or other written documents could be considered together to constitute the offer made to the heir or the legatee and his or her acceptance in connection with the acquisition and thus be considered together as an agreement in writing for purposes of the HBC. ... Generally, the minimum amount under the arrangement for a year is the FMV of property held in connection with the RRIF at the beginning of the year, multiplied by a prescribed factor for the year. ...

The loan is incurred in connection with US LLC 2’s real estate operations in Canada, which constitutes its permanent establishment in Canada, and the interest on the loan is borne by the permanent establishment. ... In each of the three scenarios above, interest paid by US LLC 2 shall be deemed to arise in Canada pursuant to Article XI(4) of the Treaty on the basis that US LLC 2 has a permanent establishment in Canada in connection with which the indebtedness was incurred, and such interest is borne by such permanent establishment. ... CRA Response The CRA response to the question posed at the 2011 IFA Conference CRA Roundtable (CRA document 2011-0404521C6) was in connection with the specific situation in which a foreign corporation (Forco) incorporated a Canadian corporation (Holdco) to acquire the shares of a Canadian corporation (Canco) which owned all the shares of an FA, and shortly thereafter Canco wound up into Holdco with Holdco then disposing of the FA shares to Forco. ...

Subsequently, on October 25, 2017 the Department of Finance released revised legislative proposals, followed on October 27 by Bill C-63 (“Bill C-63”), which expanded the scope of the tax-deferral mechanism of subsections 87(8.4) and (8.5) to also include joint elections made in connection with dispositions of certain taxable Canadian property (that is not treaty-protected property) that are interests in partnerships and interests in trusts. ... Pursuant to the October 25, 2017 draft proposals and Bill C-63, the above response would also apply for section 116 purposes in connection with valid joint elections that are filed in connection with partnership and trust interests. ... The Criminal Code also requires medical doctors and nurse practitioners providing medical assistance in dying to comply with the information filing requirements as regulated by the respective Ministry of Health in their jurisdiction, with similar filing requirements for pharmacists who dispense a substance in connection with the provision of medical assistance in dying. ...

It is anticipated that it will be required to be attached to one of the existing forms that are already required to be completed in connection with an FTS offering, such as the T100A. ... In many cases, this equipment is housed and operated in large datacenters capable of providing significant electricity and internet connections required for their use. ... Although crypto-asset mining equipment can connect directly to a blockchain network through an internet connection, most will prefer to connect to “mining pool” servers to increase their likelihood of receiving rewards. ...

Filings to amend the tax position of the trust and the beneficiary are as follows: • The trust would file Form T3A "Request for a Loss Carryback by a Trust" in connection with the loss year to request the loss be carried back to the prior year. • The trust would file Form T3-ADJ "T3 Adjustment Request" for the prior year to reflect a late subsection 104(13.1) or (13.2) designation so as to amend the trust's T3 Return. • The trust would issue amended T3 slips to the beneficiary for that prior year, reducing the income allocated. • The beneficiaries would file a Form T1-ADJ "T1 Adjustment Request" to reflect the revised T3 slip and to amend the T1 Return. ... A T3 return serves to report not only information about the reporting trust, but also additional information, such as that affecting the taxation of persons (for example, beneficiaries or settlors) having some connection to the trust. ...

Paragraph 95(3) provides that: “For the purposes of paragraph (2)(b), “services” includes the insurance of Canadian risks but does not include (b) services performed in connection with the purchase or sale of goods; The term “goods” is not defined in the Income Tax Act or the Income Tax Regulations for the purposes of paragraph 95(3)(b). ... It is also consistent with the other paragraphs which, although not using the word “goods”, refer to: (c) the transmission of electronic signals or electricity along a transmission system located outside Canada; or (d) the manufacturing or processing outside Canada […] of tangible property, or for civil law corporeal property” [emphasis added] If no other exclusions are met, 95(2)(b) would apply to services provided in connection with the sale of real estate inventory, including residential condominiums. ...

CRA Comments Generally, to be considered a supply of intangible personal property (IPP) that relates to tangible personal property (TPP), there must be a direct connection between the IPP and the TPP. ... Subject to the definition of real property in subsection 123(1) of the ETA, to be considered a supply of IPP that relates to real property for purposes of section 9 of the Regulations, there must be a direct connection between the IPP and the real property. ... VendorCo will not pay or receive any consideration from Corporation A and Corporation B in connection with these agreements. ...

What is the current CRA work situation in connection with the conduct of international audits and requests for foreign based information? ...

The donor will also wish to ensure that the value of any advantage received in connection with the gift can be verified so that an amount can be recognized as a qualifying amount of a gift. ... In addition, the tax consequences under paragraphs 84.1(1)(a) and 84.1(1)(b) will apply only if the shares of the capital stock of Target had an increase in value prior to 1971 or a capital gains deduction was claimed by the individual or a person not dealing at arm's length with the individual in connection with a previous disposition of the shares of the capital stock of Target. ...

What actions did the taxpayer take in connection with the reduction in value or the increase in cost? ...