Search - connection

Principal Issues: Does the wording of subparagraph 149(1)(o.2)(i) of the Act restrict the activities of a corporation that was incorporated before Nov. 17, 1978 solely in connection with, or for the administration of, a registered pension plan? ... For example, the wording of paragraph 149(1)(o.1) refers to a corporation incorporated and operated solely for the administration of a registered pension plan, whereas, subparagraph 149(1)(o.2)(i) refers to a corporation incorporated solely in connection with a registered pension plan or a corporation incorporated solely for the administration of a registered pension plan. ... However, in our opinion, if the corporation was incorporated in XXXXXXXXXX and was incorporated solely in connection with, or for the administration of, a registered pension plan, the business activities of the corporation would not be restricted for purposes of subparagraph 149(1)(o.2)(i) of the Act. ...

Principal Issues: Are reasonable allowances for the use of a motor vehicle in connection with the duties of an office or employment that are based on a per-kilometer rate for travel outside the metropolitan area and a flat rate for travel inside the metropolitan area taxable benefits? ... The amount based upon a flat rate for travel within the metropolitan area is deemed not to be reasonable by virtue of paragraph 6(1)(b)(x) of the Act 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, and therefore it is a taxable benefit. ... Subparagraph 6(1)(b)(x) of the Act deems an allowance not to be reasonable where the measurement of the use of the vehicle is not based solely on the number of kilometres for which it is used in connection with or in the course of the office or employment. ...

Reasons: The dividend income paid to USco is not derived from Canada in connection with or incidental to the trade or business of USco. 2019 International Fiscal Association Conference CRA Roundtable Question 8 – Active Trade or Business Test under the LOB Clause Paragraph 3 of Article XXIX-A (this Article hereinafter referred to as the “LOB Clause”) of the Canada-U.S. Tax Convention (the “Treaty”) generally provides that a U.S. resident, that is not a qualifying person under paragraph 2 of the LOB Clause and that is engaged in the active conduct of a trade or business in the U.S., can claim Treaty benefits with respect to items of income that are derived from Canada in connection with or incidental to that trade or business, provided a number of other conditions are met. In a situation where a corporation resident in Canada (“Canco”) pays a dividend to its U.S. resident parent corporation (“USco”), would paragraph 3 of the LOB Clause apply in connection with the dividend paid to USco if such income is indirectly derived through the business of Canco’s foreign affiliate (“FA”) that is a resident in a third country? ...

They import such meanings 'in relation to', 'with reference to' or 'in connection with'.  The phrase 'in respect of' is probably the widest of any expression intended to convey some connection between two related subject matters. ... There is no requirement that the revenue guarantee have any connection with either the production of the video or the ownership of the video.   ...

They import such meanings `in relation to', `with reference to' or `in connection with'. The phrase `in respect of' is probably the widest of any expression intended to convey some connection between two related subject matters. ... There is no requirement that the revenue guarantee have any connection with either the production of the video or the ownership of the video. ...

Secondly, the recent amendments to Subsection 6(2) of the Act, which defines the "reasonable standby charge", now restricts the entitlement to a reduced standby charge to those employees whose use of the automobile, as measured in kilometres driven, in connection with the duties of his employment is at least 90%. In this regard, the wording of subsection 6(6) of the Act does not support your assumption that the kilometres driven between the principal residence and the specia1 work site would be considered as kilometres driven in connection with the duties of employment. Consequently, in each of the examples provided by you the distance travelled in connection with the duties of employment would be limited to 10,000 kilometres, well under the 90% of total kilometres needed to become entitled to a reduced standby charge. ...

All contributions made under the EBP after the establishment of the Statutory Arrangement and all property that can reasonably be considered to derive from those contributions are deemed to be property held in connection with the Statutory Arrangement and not in connection with the Existing Arrangement. Therefore, income from the property (including a deferred annuity) in connection with the Existing Arrangement will be subject to the provisions of the Act dealing with an EBP. ... On the other hand, income from the property (including a deferred annuity) in connection with the Statutory Arrangement will be subject to the new RCA provisions of the Act. ...

You advised during a subsequent telephone conversation XXX Dodd) that the employee benefit plan texts were merely supplied for purposes of general information in connection with certain registration matters. You confirmed that as such, no comment from this office was required in connection with these plans and accordingly, we are closing our file. ...

Income Tax Convention exempts such payments made to a U.S. resident from Canada tax except where the information is provided in connection with a rental or franchise agreement. ... (b)Would a licence of information concerning industrial, commercial or scientific experience combined with a licence of computer software for use in dealing with the information be considered to be "in connection with a rental agreement"? ... (b) Again, it is a question of fact whether or not such an arrangement would be considered to be "in connection with a rental...agreement". ...

One test is that the individual perform all or substantially all the duties of his employment outside Canada "... in connection with a contract under which the specified employer carried on business outside Canada with respect to... ... The expressions "in connection with" and "with respect to" are considered to have very broad meanings. ... Department's Position Non-operating support personnel, who otherwise meet the criteria set out in section 122.3 of the Act and who were employed by a specified employer in connection with a contract under which the specified employer carried on a business outside Canada in a qualified activity, will be eligible to claim the OETC. ...