Search - connection

Principal Issues: (a) Is an allowance for the use of a motor vehicle in connection with the duties of an office or employment, based on a per-kilometer amount, a taxable benefit when it is adjusted to a minimum amount per round trip? (b) Is an allowance for the use of a motor vehicle in connection with the duties of an office or employment, based on a per-kilometer amount, a taxable benefit when in the previous month an employee may have received a fixed amount plus a per-kilometer amount allowance? ... Further, the fixed rate allowance for travel within the employment district is taxable since it is not based solely on the number of kilometers for which the vehicle is used in connection with or in the course of the office or employment. ...

The phrase "in connection with or in the course of the office or employment" is not defined in the Act. ... The Concise Canadian Oxford Dictionary does not define the phrase "in connection with or in the course of the office or employment" but does define the phrases "in connection with" and "in the course of". This dictionary defines "in connection with" as "with reference to" and defines "with reference to" as "regarding; as regards". ...

Tax Treaty Principal Issues: 1) Would income derived "in connection with" a U.S. trade or business include income derived from a "complementary business" as described in the 2006 U.S. ... Position: 1) Yes- in determining whether Canadian-source income is derived in connection with an active U.S. trade or business the CRA will be guided by the Technical Explanation to Article XXIX A(3) of the Canada-U.S. ... Model Income Tax Convention; 2) A portion of the gain would be considered not to be derived in connection with the U.S. trade or business. ...

They import such meanings as "in relation to", "with reference to" or "in connection with". ... 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. ... The Queen, 83 DTC 5041 (SCC), you have submitted that the words "in connection with", found in paragraph 95(3)(b), convey only some connection between two related subject matters, not necessarily a direct connection". ...

26 May 2010 External T.I. 2009-0342961E5- Computation of the RRIF Minimum Amount Unedited CRA Tags 146.3(1) Principal Issues: How is the minimum amount calculated when the property held in connection with a RRIF has no value? ... You have requested clarification of the calculation of the minimum amount under the RRIF if the fair market value of all the properties held in connection with the RRIF is nil. ... The determination of the fair market value of all properties held in connection with the RRIF is a question of fact. ...

X remains an employee of ACo but also has an opportunity for employment with Canco in Canada in connection with a directional drilling contract secured by Canco with a person unrelated to Aco. ... When the aggregate of the employment duties performed outside Canada in connection with ineligible activities and those performed in Canada in connection with any activity represent more than 10% of all the employment duties, the individual will not meet the "all or substantially all" test. ... X outside Canada in connection with his employment with ACo is 90% or more of all of his employment duties performed for ACo during a qualifying period, Mr. ...

Our position is: (a) The phrase "for use in connection with television" as used paragraph 212(5)(b) of the Act is not limited to television broadcasting. The only restriction on the application of paragraph 212(5)(b) is where a film, videotape or other means of reproduction for use in connection with television is solely in connection with and as a part of a news program produced in Canada. ... Royalties in respect of the production or reproduction of motion pictures or videotapes which are not for private (home) use, including but not limited to those used in connection with television broadcasting, are not exempt. ...

What are to be considered activities that would be carried on in Canada in connection with the exploration or exploitation of the seabed and subsoil and their natural resources ("in connection with the offshore resources")? ... Transportation activities (e.g. ferrying of supplies and personnel) in connection with the offshore resources fall within paragraph 2 of Article XXVIIA. ... The wording "in respect of an employment exercised aboard a tugboat or similar vessel in connection with such activities" as used in paragraph 5(b) is unclear. ...

What are to be considered activities that would be carried on in Canada in connection with the exploration or exploitation of the sea bed and subsoil and their natural resources ("in connection with the offshore resources")? ... Transportation activities (e.g. ferrying of supplies and personal) in connection with the offshore resources fall within paragraph 2 of Article XXVIIA. ... The wording "in respect of an employment exercised aboard a tugboat or similar vessel in connection with such activities" as used in paragraph 5(b) is unclear. ...

Principal Issues: Whether debts "incurred in connection with the purchase and sale of investments... ... Our Comments Paragraph 149.1(4)(d) of the Income Tax Act refers to a debt "incurred in connection with the purchase and sale of investments... ... In particular, in our view, loans obtained or debts incurred for the purpose of permitting a public or private foundation to purchase investments are not debts "incurred in connection with the purchase and sale of investments". ...