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Reasons: The draft legislation requires that the award be received in connection with an individual's enrolment in an educational program for which the individual may claim the education tax credit. ... The draft legislation indicates that the exemption will only apply if the award is received in connection with an individual's enrolment in an educational program for which the individual may claim the education tax credit. ...

Position: No Reasons: There must be a connection between the actual travel cost and the amount received by the employer to defray those costs. 972880 XXXXXXXXXX J.E. ... " In our opinion, there must be a connection between the actual travelling expenses incurred by the taxpayer or a member of the taxpayer's household and the amounts paid by the taxpayer's employer to defray those costs. ...

In this respect, these terms suggest a connection to horses. Accordingly, it is our view that, in this context, a “stable” means “a building set apart and adapted for keeping horses.” Therefore, the phrase “stable equipment” refers only to equipment which is used in connection with a stable for horses. ...

Principal Issues: We have been asked to be of assistance with respect to the commutation of an annuity contract issued in connection with a structured settlement arrangement and the payment of the related lump sum to the claimant. ... As a result of your financial circumstances, you have asked us whether the remaining payments in respect of the two annuity contracts issued in connection with the structured settlement, could be commuted by the owner (insurer) and the two related lump sum amounts paid to you. ...

Reasons FOR POSITION TAKEN: Old Age Security income does not have any reserve connection and is taxable. ... However, old age security income does not have any reserve connection and remains taxable. ...

Our Responses In connection with the situation described in (a) above, it is our position that employees of a sub-contractor may qualify for an OETC notwithstanding the fact that the sub-contractor itself is not carrying on a qualified activity provided that their employment duties are performed outside Canada in connection with a contract under which the sub-contractor carried on business outside Canada with respect to a qualified activity. ...

Principal Issues: We have been asked to be of assistance with respect to the commutation of an annuity contract issued in connection with a structured settlement arrangement and the payment of the related lump sum to the claimant. ... As a result of your financial circumstances, you have asked us whether a portion of the payments in respect of the annuity contract in connection with the structured settlement, could be commuted by the owner (insurer) and the related lump sum amounts paid to you. ...

Principal Issues: Whether emergency vehicles used by employees to drive between their homes and their and usual workplace is otherwise than in connection with or in the course of the taxpayer's office or employment. ... It is a question of fact whether an employee has used the employer's vehicle in connection with or in the course of the employee's office or employment. ...

XXXXXXXXXX 2019-079277 XXXXXXXXXX, 2019 Dear XXXXXXXXXX: Re: XXXXXXXXXX Supplemental Advance Income Tax Ruling We are writing in connection with our recent discussions (XXXXXXXXXX) in regard to our advance income tax ruling number 2018-077896, that was issued to the above-referenced taxpayer on XXXXXXXXXX (the “Original Ruling”). ... An invoice for our fees in connection with this supplementary ruling request will be forwarded to you under separate cover. ...

Subparagraph 3(d) of article XI the Convention provides that interest arising in a Contracting State shall be exempt from tax in that State if:      "the interest is beneficially owned by seller who is a resident of the other Contracting State and is paid by a purchaser in connection with the sale on credit of any equipment, merchandise or services, except where the sale is made between persons dealing with each other not at arm's length;" You have asked for our views as to whether the word "seller" in the above mentioned provision can be interpreted to include the assignees of the seller who hold the purchase money paper created in connection with "a sale on credit of equipment, merchandise or services" made at arm's length if a)     the assignment is contemporaneous with or subsequent to such a sale, or b)     the assignment is made with or without recourse to the seller/assignor by the assignee. ...