Search - connection

The fact that a corporation, carrying on an active business and holding certain property (i.e. investments) unrelated to the business, uses the income from property in connection with the operation of the active business does not mean that the property is "incident to or pertains to" the active business. ...

He stated at page 89      "I think the real question is, was there any inter-connection, any interlacing, any inter-dependence, any unity at all embracing those two businesses;". ...

The case concerned a Swedish taxpayer operating a consulting company that was hired in connection with the hook-up of a drilling platform on the Norwegian continental shelf. ...

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. ...

30 October 1986 Income Tax Severed Letter 5-1782 Dear Sirs: This is in reply to your letter of June 20, 1986 in which you requested our opinion on the application of certain provisions of the Income Tax Act (the "Act") in connections with the following assumed facts: In 1971, a taxable Canadian corporation (Canco) incorporated a company in the Netherlands (BV). ...

In general terms they are as follows: (a) it must not, in the opinion of the Minister, be a charity; (b) it must be organized exclusively for social welfare, civic improvement, pleasure, recreation or any other purpose except profit; (c) it must in fact be operated exclusively for the same purpose in (b) for which it was organized or for any of the other purposes mentioned in (b); and (d) no part of its income may be paid, payable or otherwise made available for the personal benefit of any proprietor, member or shareholder, except in connection with the promotion of amateur athletics in Canada. ...

In connection with the possible application of subsection 110.6(8) of the Act, even if shares are not prescribed shares it may be that any capital gain on their disposition is not attributable to the fact that dividends were not paid on the shares and thus subsection 110.6(8) may not apply. ...

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

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. ...

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. ...