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However, there must be a direct connection between the supplies acquired and the activities engaged in by the person. ... Under subparagraph 6(1)(b)(v), (vi), (vii) or (vii.1) of the ITA, the following allowances are excluded from an income from office or employment: reasonable allowances for travel expenses received by an employee from the employer in connection with the selling of property or negotiating of contracts for the employee’s employer; reasonable allowances received by a minister or clergyman in charge of or ministering to a diocese, parish or congregation for expenses for transportation incident to the discharge of the duties of that office or employment; reasonable allowances for travel expenses (other than allowances for the use of a motor vehicle) received by an employee (other than an employee employed in connection with the selling of property or the negotiating of contracts for the employer) from the employer for travelling away from the municipality where the employer’s establishment at which the employee ordinarily worked or to which the employee ordinarily reported was located, and the metropolitan area, if there is one, where that establishment was located, in the performance of the duties of the employee’s office or employment; and reasonable allowances for the use of a motor vehicle received by an employee (other than an employee employed in connection with the selling of property or the negotiating of contracts for the employer) from the employer for travelling in the performance of the duties of the office or employment. ... Under subparagraphs 6(1)(b)(x) and (xi) of the ITA, an allowance paid to an employee for the use of a motor vehicle in connection with the activities of the employer is considered to be reasonable only if the following conditions apply: the allowance is based only on the number of kilometres driven in a year in connection with, or in the course of, an office or employment; the rate per kilometre is reasonable; and the employee is not reimbursed for expenses related to the same use of the motor vehicle, other than a reimbursement for supplemental business insurance, toll or ferry charges, not already included in the allowance. ...

The Directorate will not provide any written comments in connection with a Pre-ruling Consultation. ... This consent will also apply to a supplemental ruling issued in connection with the initial Ruling. ... In making this request, we acknowledge and confirm our acceptance of the following terms: A Pre-ruling Consultation will only be considered in connection with a proposed transaction. ...

If for example, expenses are paid by a parent company on behalf of its subsidiary, in connection with the issuance of shares by its subsidiary, they are not deductible by the parent company under paragraph 20(1)(e). ... For expenses to qualify under paragraph 20(1)(e), in connection with the issuance or sale of shares, it is not necessary for the taxpayer to obtain additional capital by the issuance or sale of shares. ... When a corporation, partnership, or syndicate enters into a transaction described in ¶ 2(a), the expenses listed below would be deductible under subparagraph 20(1)(e)(i) in computing income for the year in which they are incurred: (a) legal fees in connection with the preparation and approval of a prospectus pertinent to the issuance or sale of shares, units, or interests; (b) accounting or auditing fees in connection with the preparation of reports on financial statements and statistical data for inclusion in, or for presentation with, the prospectus; (c) the cost of printing the prospectus, new share, unit, or interest certificates, etc; (d) registrars' or transfer agents' fees; and (e) filing fees charged by any public regulatory body which requires the filing of a prospectus for acceptance. ¶ 17. ...

The Directorate will not provide any written comments in connection with a Pre-ruling Consultation. ... This consent will also apply to a supplemental ruling issued in connection with the initial Ruling. ... In making this request, we acknowledge and confirm our acceptance of the following terms: A Pre-ruling Consultation will only be considered in connection with a proposed transaction. ...

However, there must be a direct connection between the supplies acquired and the activities engaged in by the person. ... Under subparagraph 6(1)(b)(v), (vi), (vii) or (vii.1) of the ITA, the following allowances are excluded from an income from office or employment: reasonable allowances for travel expenses received by an employee from the employer in connection with the selling of property or negotiating of contracts for the employee’s employer; reasonable allowances received by a minister or clergyman in charge of or ministering to a diocese, parish or congregation for expenses for transportation incident to the discharge of the duties of that office or employment; reasonable allowances for travel expenses (other than allowances for the use of a motor vehicle) received by an employee (other than an employee employed in connection with the selling of property or the negotiating of contracts for the employer) from the employer for travelling away from the municipality where the employer’s establishment at which the employee ordinarily worked or to which the employee ordinarily reported was located, and the metropolitan area, if there is one, where that establishment was located, in the performance of the duties of the employee’s office or employment; and reasonable allowances for the use of a motor vehicle received by an employee (other than an employee employed in connection with the selling of property or the negotiating of contracts for the employer) from the employer for travelling in the performance of the duties of the office or employment. ... Under subparagraphs 6(1)(b)(x) and (xi) of the ITA, an allowance paid to an employee for the use of a motor vehicle in connection with the activities of the employer is considered to be reasonable only if the following conditions apply: the allowance is based only on the number of kilometres driven in a year in connection with, or in the course of, an office or employment; the rate per kilometre is reasonable; and the employee is not reimbursed for expenses related to the same use of the motor vehicle, other than a reimbursement for supplemental business insurance, toll or ferry charges, not already included in the allowance. ...