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While common-law principles would establish that only one property exists when something built on land has a substantial connection with it, and the purpose of that construction is to effect a permanent improvement upon the land, the component parts of the property (for instance, land and building) may, nonetheless, be considered separately for tax purposes in certain situations. ...

The 10% Coverage under a PHSP The CRA considers a plan to be a PHSP where the following conditions are met: All of the expenses covered under the plan are: medical and hospital expenses (medical expenses) expenses incurred in connection with a medical expense and within a reasonable time period following the medical expense (connected expenses) a combination of medical expenses and connected expenses. ...

Based on this assumption, you have asked us to provide our comments regarding the income tax treatment for both employees and the Employer of the Plan in connection with the salary deferral amounts, the notional contributions, the benefit payments and the possible forfeitures or lump sum withdrawals under the Plan. ...

Furthermore, the courts have also stated that connections that are artificial should not be given weight in determining the location of income for purposes of the exemption. ...

The CRA’s long-standing position regarding the tax consequences of a settlement payment made to a registered plan in respect of an actionable loss suffered in connection with a plan investment is that the payment is not a contribution, premium or gift to the plan and will not result in an income inclusion to the plan’s controlling individual. ...

Each of these "connections" is, in turn, statutorily defined (subsection 251(6) of the Act).  ...

The general principles stated in this bulletin and established by the courts for foreign currency transactions are the following: a)     where the gain or loss arises in connection with the purchase or the sale of property or services, the nature of the gain and loss will be determined by the nature of the transaction.  ...

In this connection, we agree that it would also be reasonable to reduce the income taxes on the $200,000 as otherwise determined by a pro rated portion (based on the number of days in the 1989 stub period as a proportion of the total number of days in Co.'s 1989 taxation year of 16% of the least of the amounts referred to in subsection 125(1) of the Act, but subject to subsections 125(2) and (3) of the Act. 2.      ...

It is our position that the following two conditions must be met in order for payments for any services, including a hotline service, provided in connection with the use of computer software not to be considered part of the software licence fee which is subject to Part XIII tax: (i)     The acquisition of the services should be optional.  ...

In connection with your observation that the word "indebtedness" has been substituted for the words "bond, debenture, bill, note, mortgage, hypothec or similar obligation" in the definitions of "qualified small business corporation share" and "small business corporation" in subsections 110.6(1) and 248(1) of draft legislation released by the Department of Finance on July 13, 1990 (now Bill C-18 which received First Reading on May 30,1991), we agree that "indebtedness" has a more general meaning than the words it is replacing. ...