Search - connection

A building must be used in connection with the earning of business income or property income in order for mortgage interest expenditures to be deductible.  If the building is not being used for income-earning purposes, as in the case of a personal residence for example, then expenditures incurred in connection with the property would not be deductible. ...

You further enquire as to whether an employee covered by an individual RPP could deduct any expenses paid by him in connection with establishing the RPP. ... In our opinion, an employee is not entitled to deduct expenses paid in connection with establishing an individual RPP since these expenses belong to the employer or the trustee of the RPP. ...

8 July 1981 Income Tax Severed Letter RCT 3-6201 F Unedited CRA Tags 85 Section 85Elections As discussed with you recently, enclosed herewith are the memorandum and related documentation received from the Saskatoon District Office in connection with the above-noted taxpayer. ... We await your comments in this matter and shall be pleased to provide any further assistance you may require in this connection. ...

We agree that the provisions of the said Article XIIIC exempt from tax, otherwise imposed by subsection 212(5) of the Income Tax Act, payments made for the right in or to the use of a videotape for use in connection with television broadcasting. ... In this context, it is your view that the exemption should continue to apply if "a motion picture is first filmed and then transferred to video tape for editing and other production and post-production work, with the final version remaining on video tape for use in connection with television". ...

We are now, after further consideration, of the opinion that the income of a foreign affiliate should only be accepted, for the purposes of subparagraph 95(2)(a)(i), as pertaining or being incident to the active business of a related foreign affiliate in very rare and unusual circumstances where the taxpayer substantiates that there is a direct connection between the income of the foreign affiliate and the active business of the related foreign affiliate. Based on our review of the information that has been provided to us, we do not feel that the taxpayer has substantiated that there is a direct connection between the interest income of XXX and the active businesses of any of its related foreign affiliates and on that basis we are in agreement with you that subparagraph 95(2)(a)(i) is not applicable and that the interest income is foreign accrual property income. ...

It is our understanding that XXX In order for an individual to be eligible to claim the OETC, in addition to meeting other conditions set out in subsection 122.3(1) of the Income Tax Act (the “Act”), the individual is required to 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 in such country or countries with respect to the qualified activities set out in paragraph 4(c) of Interpretation Bulletin IT-497R2. Based on the limited facts provided in your letters of October 25 and November 29, 1991 XXX In order for you to qualify for the OETC it would be necessary for XXX to demonstrate that they are carrying on business in Mexico in connection with a contract with respect to one or more of the qualified activities. ...

New paragraph 85(1)(c.2) of the Act as enacted by Bill C-18 applies where a taxpayer carrying on a farming business, the income from which is computed in accordance with the cash method, transfers to the corporation property, which was inventory owned in connection with that farming business immediately before the transfer of the property to the corporation. ... Pursuant to new subparagraph 85(1)(c.2), a growing crop of plants acquired on a subsection 85(1) rollover by a corporation in connection with a cash method farming business would be purchased inventory of the corporation for purposes of paragraph 28(1)(c) of the Act. ...

You further enquire as to whether an employee covered by an individual RPP could deduct any expenses paid by him in connection with establishing the RPP. ... In our opinion, an employee is not entitled to deduct expenses paid in connection with establishing an individual RPP since these expenses belong to the employer or the trustee of the RPP. ...

Question (d) Whether the position be different if the bonus or salary was paid to the beneficiary of the freeze in the ordinary course of the corporation's business or in connection with a post-freeze asset sale by the corporation. ... The payment by the corporation of a bonus or salary to the beneficiary of the freeze in connection with a post freeze asset sale by the corporation, and such a bonus or salary is not commensurate with the value of the services performed and the responsibilities assumed by the beneficiary of the freeze. ... (d) Would your position be different if the bonus or salary was paid to the beneficiary of the freeze in the ordinary course of the corporation's business or in connection with a post-freeze asset sale by the corporation? ...

.; (b) "Client" means the XXXXXXXXXX; (c) "Contract" means the XXXXXXXXXX-year lease contract for the Product as described in paragraph 3 below; (d) "Country 1" means XXXXXXXXXX; (e) "Country 2" means XXXXXXXXXX; (f) "CRA" means the Canada Revenue Agency; (g) "Overseas Employees" means the employees of Aco who will perform their employment duties in Country 1 in connection with the Contract; (h) "OETC" means the overseas employment tax credit in section 122.3 of the Act; (i) "Product" means the XXXXXXXXXX; (j) "Subcontractor" means XXXXXXXXXX; and (k) "Subcontractor Supervisor" means the employee of Aco who will carry out certain activities in Country 2 in connection with the Contract. ... In connection with its obligations under the Contract, Aco will send an XXXXXXXXXX ("Subcontractor Supervisor") to Country 2 for a continuous period of XXXXXXXXXX to supervise the Subcontractor. ... The activities described in 9(a) to 9(d) and 13(a) to 13(e) above will represent more than 50% of all activities that will be undertaken by Aco in Country 1 and Country 2 in connection with the Contract. 16. ...