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The fees of a specialist, although not a lawyer or notary, who negotiates a reduction of the mortgage prepayment penalty, would generally qualify under subsection 62(3) as an eligible moving expense when paid in connection with the sale of the old residence. ...

Nevertheless, we offer the following general comments in connection with your request which we hope are of assistance to you. ...

Grisé Attention: XXXXXXXXXX November 24, 1999 Dear Sirs: Re: Replacement Property Rules This is in reply to your letter of September 9, 1999, requesting a technical interpretation in connection with the application of the replacement property rules to a hypothetical situation. ...

Generally, expenses that may be deducted by a personal services business are: any salary, wages, benefit, or allowance the corporation provides to its incorporated employee(s); amounts paid by the corporation in connection with the negotiating of contracts, as long as the amount would have been deductible from employment income if it had been paid by the incorporated employee under a contract of employment that required the employee to pay the amount; and legal expenses the corporation incurs for collecting amounts owing to it. ...

One of these exceptions is for an interest in a trust that is established in connection with a foreign plan that provides pension, retirement or employee benefits where the trust is exempt from income tax imposed by the country of its residence and is maintained primarily for the benefit of non-resident individuals. ...

Leung   (613) 957-2116 September 11, 1989 Dear Sirs: Re:  Subsection 55(2) and Part IV of the Income Tax Act (the "Act") This is in reply to your letter of July 26, 1989 wherein you requested our opinion with respect to the application of subsection 55(2) and Part IV of the Act in connection with the following hypothetical fact situation. 1.      ...

Specifically, you requested the Department's views as to whether the field of architecture is qualified activity and whether an employer would be considered to be carrying on a business in a foreign country to which an employee was sent to perform duties in connection with a contract under which the employer provided architectural services to a construction company resident in that country. ...

Subsection 67.1(1) of the Act contains the words "in respect of which we interpret to mean in relation to or in connection with. ...

As described in paragraph 3 of Information Circular IC 89-4, paragraph 237.1(1)(b) of the Act defines a tax shelter as any property of which it is expected, based on statements or representations made or proposed to be make in connection with the property, that the aggregate of losses or other amounts, calculated in any of the relevant years, which a purchaser will be entitled to deduct in taxation years ending within four years of the date of acquisition of the property will exceed the cost of the interest in the property (less prescribed benefits) to the purchaser.  ...

28 May 1991 Ministerial Letter 91M05088 F- Price Adjustment Clauses Unedited CRA Tags 85 Q.15 Price Adjustment Clauses Price adjustment clauses are commonly used in connection with shares issued in the context of section 85 rollovers.  ...