Search - connection

To function as a cogeneration system, each micro-turbine requires a connection to the gas supply, electrical, primary heating and control systems of the greenhouse. ... With regard to the natural gas connection, the gas main to the greenhouse does not only serve the micro-turbine units, and the system boundary for the gas connection is where the gas enters the micro-turbine units. Therefore, in our view, none of the costs of the gas supply connections are eligible for Class 43.1. ...

Reasons: It had been our view that the phrase "debts incurred in connection with the purchase and sale of investments" should be interpreted strictly. ... In a memorandum to you dated June 30, 2005, we discussed the meaning of the phrase "debts incurred in connection with the purchase and sale of investments" in paragraphs 149.1(3)(d) and (4)(d) of the Income Tax Act. ... Jurisprudence has confirmed that the phrase "in connection with" has a very broad meaning (see the Supreme Court of Canada commentary in that regard in Nowegijick v. ...

Reasons: Considered incidental, connection insufficient. December 8, 1998 Client Services Directorate HEADQUARTERS Ministerial Correspondence Division D. ... Where less than 90% of the duties are performed on a reserve the exemption can be prorated, however, there still must be a sufficient connection to consider that part of the employment is situated on the reserve. ... Where the time on the reserve consists of irregular intervals of short amounts of time, we would likely consider the connection to be incidental and, therefore, the income would be fully taxable. ...

Principal Issues: Interpretation of phrase "restructuring of debt in connection with a proceeding commenced in a court in Canada before February 22, 1994" as that phrase is used in the draft legislation to amend section 80. Position TAKEN: Restructuring of debt can occur subsequent to court proceeding provided it is in connection with that court proceeding which commenced prior to Feb. 22, 1994. ... Any negotiated settlement and restructuring, that is in connection with that court proceeding, could occur subsequent to February 22, 1994. ...

Principal Issues: Are minimum amounts that are paid to employees, for the use of a motor vehicle in connection with the duties of an office or employment, taxable benefits where the amount is not based solely upon a per-kilometer calculation? ... Subparagraph 6(1)(b)(x) of the Act deems the allowance not to be reasonable if the measurement of the use of the vehicle is not based solely on the number of kilometres for which the vehicle is used in connection with or in the course of the office or employment. Where a minimum amount is paid for a round trip that is not based solely on kilometers used, it would have to be determined whether this amount (even when it is a nominal amount) is paid to employees to compensate them for the actual expenses incurred in using their motor vehicle in connection with the duties of the office or employment for any given day. ...

Furthermore, it is our view that the term "in connection with television" is very broad and would encompass both videotapes used for private (home) use as well as videotapes used in television broadcasting. It should be noted that the Federal Budget of February 10, 1988 proposes to amend subsection 212(5) of the Act to add the words "or other means of reproduction" in paragraph 212(5)(b) between the words "videotape" and "for use in connection with television". ... We would also point out that the Second Protocol of the Canada-United Kingdom Income Tax Convention amended paragraph 4 of Article XII by adding the word "broadcasting" after the phrase "for use in connection with television". ...

Specifically, you requested our views whether the loan described above would be considered, for purposes of paragraph 149(4)(d) of the Act, a debt incurred in connection with the purchase and sale of investments. ... In any specific case the determination as to whether debts are incurred "in connection with" the purchase and sale of investments is a question of fact to be determined on the basis of all the details in that case. In our view the words "in connection with" contemplate a direct relationship between the incurring of the debt and the purchase and sale of investments. ...

Officials of the Department of Finance advised us that during the Canada-United States negotiations it was agreed that the words "for use in connection with television" should be restricted. ... Finance officials were primarily concerned with television broadcasting, and were prepared to give up the right to tax royalties paid in connection with the rental of video cassettes for private viewing. ... Given this background and the fact that the Second Protocol to the Canada-United Kingdom Income Tax Convention amends paragraph 4 of Article XII by adding the word "broadcasting" after the phrase "for use in connection with television" it can be concluded that the same intention should be ascribed to the relevant words in the United States Convention. ...

Specifically, you requested our views whether the loan described above would be considered, for purposes of paragraph 149(4)(d) of the Act, a debt incurred in connection with the purchase and sale of investments. ... In any specific case the determination as to whether debts are incurred "in connection with" the purchase and sale of investments is a question of fact to be determined on the basis of all the details in that case. In our view the words "in connection with" contemplate a direct relationship between the incurring of the debt and the purchase and sale of investments. ...

Specifically, you requested our views whether the loan described above would be considered, for purposes of paragraph 149(4)(d) of the Act, a debt incurred in connection with the purchase and sale of investments. ... In any specific case the determination as to whether debts are incurred "in connection with" the purchase and sale of investments is a question of fact to be determined on the basis of all the details in that case. In our view the words "in connection with" contemplate a direct relationship between the incurring of the debt and the purchase and sale of investments. ...