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Current CRA website
Instructions for applying for a tax shelter identification number
Representations made in connection with the property Gifting arrangements Appraisals for donations of gifts in kind Who has to register a tax shelter? ... Generally, a gifting arrangement is any arrangement under which it may reasonably be considered, based on statements or representations made or proposed to be made in connection with the arrangement, that a person entering into the arrangement would do one of the following: a) make a gift to a qualified donee, or make a political contribution, of property acquired by the person under the arrangement b) incur a limited-recourse debt that can reasonably be considered to relate to a gift to a qualified donee or a political contribution A political contribution refers to a monetary contribution to a registered party, a registered association, or a candidate as defined in the Canada Elections Act. ... Representations made in connection with the property The definition of what constitutes a tax shelter depends entirely on the reasonable inferences that we can draw from representations made in connection with the property. ...
Current CRA website
Income Tax Act – Authorization to exercise powers or perform duties of the Minister of National Revenue
Subsection 67.5(2) Non-deductibility of illegal payments- May may make such assessments, reassessments and additional assessments of tax, interest and penalties and such determinations and redeterminations as are necessary to give effect to subsection 67.5(1) Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Paragraph 70(5.2)(c) Resource property and land inventory of a deceased taxpayer- May extend the period for showing that property has become vested in the spouse, common-law partner or trust Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Team Leader, Audit Subsection 70(6) Transfer or distribution of property on death- May determine a longer period that is considered reasonable in the circumstances for showing that property has become vested in a spouse, common-law partner or trust Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Team Leader, Audit Subsection 70(6.1) Transfer or distribution of net income stabilization account on or after the death of a taxpayer –May determine any longer period that is considered reasonable in the circumstancesfor showing that property has become vested indefeasibly in a spouse, common-law partner or trust Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Team Leader, Audit Paragraph 70(9)(c) Death of a taxpayer – May determine any longer period that is considered reasonable in the circumstances for a transfer of property to a child of the taxpayer Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Team Leader, Audit Paragraph 70(9.1)(e) Death of a beneficiary- May determine any longer period that is considered reasonable in the circumstances for a transfer of property from a trust to a settlor’s child Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Team Leader, Audit Paragraph 70(9.2)(c) Death of a taxpayer – May determine any longer period that is considered reasonable in the circumstances for a transfer of a family farm, fishing corporation or partnership to a child of the taxpayer Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Team Leader, Audit Paragraph 70(9.3)(e) Death of a beneficiary – May determine any longer period that is considered reasonable in the circumstances for a transfer of a family farm or fishing corporations or family farm or fishing partnerships from a trust to a settlor’s child Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Team Leader, Audit Paragraph 80(2)(i) May designate the order of settling of commercial obligations if the debtor does not so designate Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Team Leader, Audit Subsection 80(16) May designate amounts under subsections 80(5) to (11) to the extent that the debtor would have been permitted to designate those amounts Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Team Leader, Audit Paragraph 81(4)(b) May demand an employer’s written certification in connection with an individual’s volunteer services Headquarters Positions Director General, Collections and Verification Branch Director General, Compliance Programs Branch Director, Collections and Verification Branch Director, Compliance Programs Branch Manager, Collections and Verification Branch Manager, Compliance Programs Branch Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Manager, Compliance Team Leader, Audit Team Leader, Processing/Services Team Leader, T1 Processing Team Leader, Verification History: Delegation in respect of paragraph 81(4)(b) was amended on October 19, 2020. ... Clause 139.1(2)(h)(ii)(E) May accept another day as the latest day by which a stakeholder is considered to receive a benefit in connection with a demutualization of an insurance corporation Headquarters Positions Director General, Assessment, Benefit, and Service Branch Director General, Compliance Programs Branch Director, Assessment, Benefit, and Service Branch Director, Compliance Programs Branch Manager, Assessment, Benefit, and Service Branch Manager, Compliance Programs Branch Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Team Leader, Audit History: Delegation in respect of clause 139.1(2)(h)(ii)(E) was amended on November 24, 2021 and October 19, 2020. ... Subsection 241(6) May appeal an order or direction made in the course of, or in connection with, legal proceedings requiring an official or other representative of a government entity or authorized person to give or produce evidence relating to any taxpayer information Headquarters Positions Director General, Appeals Branch Director General, Charities Directorate Director General, Collections and Verification Branch Director, Collections and Verification Branch Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Chief of Appeals Manager, Appeals Manager, Litigation Team Leader, Appeals Team Leader, Litigation Subsection 241(9.3) May, in connection with a program, activity or service provided or undertaken by the Minister, make available to the public the business number and the name of the holder of a business number Headquarters Positions Director General, Assessment, Benefit, and Service Branch Director, Assessment, Benefit, and Service Branch Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Business Returns Manager, Business Returns and Specialty Services History: Delegation in respect of subsection 241(9.3) was amended on November 24, 2021. ...
Old website (cra-arc.gc.ca)
Delegation under the
Subsection 241(6) May appeal an order or direction made in the course of or in connection with legal proceedings requiring an official or other representative of a government entity or authorized person to give or produce evidence relating to any taxpayer information Headquarters Positions Director General, Charities Directorate Director General, Collections Director General, Debt Management Compliance Director General, Tax and Charities Appeals Directorate Director, Collections Director, Non-Filer/Non-Registrant Field Positions Director, Tax Services Office Chief of Appeals Manager, Appeals Manager, Litigation History: Delegation in respect of subsection 241(6) was amended on November 6, 2014. ... Subsection 241(9.3) May, in connection with a program, activity or service provided or undertaken by the Minister, make available to the public the business number and the name of the holder of a business number Headquarters Positions Director General, Business Returns Director, Business Registration and Corporation Programs Division Field Positions Director, Tax Centre Assistant Director, Tax Centre Manager, Business Registration History: Delegation in respect of subsection 241(9.3) was amended on May 6, 2013. ... Paragraph 8502(g) Conditions applicable to all plans- May accept an arrangement under which a property is held in connection with a plan Headquarters Positions Director General, Registered Plans Directorate History: Delegation in respect of paragraph 8502(g) was amended on June 16, 2004. ...
Conference
8 April 2009 Roundtable, 2008-0272371C6 - Limitation of Benefits
" How will Canada interpret the reference to "in connection with or incidental to" in applying paragraph 3 of Article XXIX A- what is the required nature of the connection, and the required degree of the connection? ... Court cases dealing with similar expressions used in the Income Tax Act "In connection with": Although the expression "in connection with" would appear to have a broad connotation, the Court indicated in the case of Gene A. ... This decision suggests that in order for an item of income to be considered derived "in connection" with an active trade or business, there should be a direct connection between the item of income and the active trade or business. ...
Miscellaneous severed letter
12 November 1997 Income Tax Severed Letter E9729770.txt - FOREIGN AFFILIATES - EXEMPT SERVICES
Principal Issues: Whether services performed by a foreign affiliate in connection with a guarantee or warrantee associated with a product sold by the taxpayer would be considered as a service performed in connection with the sale of the product for the purposes of paragraph 95(3)(b). Position: No Reasons: The service must be performed directly in connection with the sale. ... Therefore services provided by a foreign affiliate to a taxpayer in connection with either a guarantee or a warrantee associated with a product sold by the taxpayer would not qualify for the exclusion under paragraph 95(3)(b) as having been performed in connection with the sale of goods. ...
Conference
12 November 1997 Roundtable, 9729770 - FOREIGN AFFILIATES - EXEMPT SERVICES
Principal Issues: Whether services performed by a foreign affiliate in connection with a guarantee or warrantee associated with a product sold by the taxpayer would be considered as a service performed in connection with the sale of the product for the purposes of paragraph 95(3)(b). Position: No Reasons: The service must be performed directly in connection with the sale. ... Therefore services provided by a foreign affiliate to a taxpayer in connection with either a guarantee or a warrantee associated with a product sold by the taxpayer would not qualify for the exclusion under paragraph 95(3)(b) as having been performed in connection with the sale of goods. ...
Miscellaneous severed letter
21 November 1985 Income Tax Severed Letter RCT-0488 F
Subsection 212(5) provides for payment of an income tax of 25% on every amount paid for a right in or to the use of: (i) a video tape for use in connection with television (212(5)(b)). (ii) a video tape (other than for use in connection with television) that is derived from a motion picture film (212(5)(a)). Video tapes not derived from motion picture films and not for use in connection with television are exempted from the said tax. ...
Technical Interpretation - External
4 April 2024 External T.I. 2024-1004651E5 - QZETMA: Battery Separators
The qualified activities are performed in connection with the manufacturing or processing of an integral component of the powertrain of the ZEV, including batteries and fuel cells. 3. ... Qualified Activities Generally speaking, qualified activities are those that are performed in Canada directly in connection with the manufacturing or processing in Canada of goods for sale or lease (footnote 5), as well as many other activities that are specifically listed in section 5202 of the Regulations when they are performed in Canada, in connection with the manufacturing or processing in Canada of goods for sale or lease. ... In connection with the manufacturing or processing of an integral component of the powertrain of ZEV, including batteries and fuel cells The definition of QZETMA requires that the battery separator being manufactured by the taxpayer is an “integral component” of the powertrain of the ZEV, including batteries or fuel cells. ...
Miscellaneous severed letter
14 September 1990 Income Tax Severed Letter EACC9734 F - Draft Form
Parnanzone Manager (613) 957-9232 EACC9734 SUBJECT: DRAFT FORM "Designation of Retiring Allowances as Qualifying Transfers in Connection with a Past Service Event in Respect of a Defined Benefit Provision of a Registered Pension Plan" This is in reply to your round trip memorandum of August 24, 1990 concerning the review of the above-noted form. ...
Administrative Letter
11 July 1990 Administrative Letter 59496 F - Scientific Research & Experimental Development
For the SR & ED to be related to a business of the taxpayer, there must be some connection or link between the taxpayer's business carried on at the time the expenditure is made and the SR & ED carried on. ...