Search - connection

5 November 2010 External T.I. 2010-0379021E5- solely in connection with and as part of news prog Unedited CRA Tags 212(5)(b) Principal Issues: A Canadian resident corporation operates as a television channel. ... Can we say that those highlights are used "solely in connection with and as part of a news program produced in Canada" and be exempted from withholding under 212(5)(b)? ... As the Sports Highlights can be used in both types of television program categories, the payment cannot be said to be for a right that is to be used "solely in connection with and as part of a news program produced in Canada". ...

29 March 1996 External T.I. 9601725- OETC WHERE DUTIES NOT IN CONNECTION WITH QUAL. ... Reasons FOR POSITION TAKEN: Paragraph 122.3(1)(b) requires that the individual perform "all or substantially all of the duties (90% or greater) of the individual's employment outside Canada in connection with a contract... with respect to " a qualified activity. In the antithetical situation, where the individual performs more than 10% of the duties of the individual's employment outside Canada in connection with a contract with respect to an ineligible activity, the individuals' eligibility for the OETC would be denied. ...

25 November 2005 External T.I. 2005-0122351E5- Service Connection and CRCE Unedited CRA Tags Reg 1219(1) 66(12.6) Principal Issues: Whether the cost to design and purchase certain property will qualify as CRCE under paragraph 1219(1)(a) of the Regulations as having been incurred for the purpose of making a service connection to a qualifying project for the transmission of electricity to a purchaser. ... A determination by Transmission that particular costs are required to be incurred by a Generator in order to permit interconnection with the provincial transmission system is a factor to be considered in determining whether such costs were incurred for the purpose of making a service connection to the project for the transmission of electricity to a purchaser thereof as required by paragraph 1219(1)(a) of the Regulations. ... As such, notwithstanding that a cost incurred by a PBC for the purpose of making a service connection to a qualifying project may qualify for inclusion in CRCE under paragraph 1219(1)(a) of the Regulations, the PBC may be precluded from making a renunciation to a FTS investor in respect of such cost. ...

The qualified activities are performed in connection with the manufacturing or processing of an integral component of the powertrain of the ZEV, including batteries and fuel cells. 3. ... Qualified Activities Generally speaking, qualified activities are those that are performed in Canada directly in connection with the manufacturing or processing in Canada of goods for sale or lease (footnote 5), as well as many other activities that are specifically listed in section 5202 of the Regulations when they are performed in Canada, in connection with the manufacturing or processing in Canada of goods for sale or lease. ... In connection with the manufacturing or processing of an integral component of the powertrain of ZEV, including batteries and fuel cells The definition of QZETMA requires that the battery separator being manufactured by the taxpayer is an “integral component” of the powertrain of the ZEV, including batteries or fuel cells. ...

Therefore services provided by a foreign affiliate to a taxpayer in connection with either a guarantee or a warrantee associated with a product sold by the taxpayer would not qualify for the exclusion under paragraph 95(3)(b) as having been performed in connection with the sale of goods. ... The Queen, 83 DTC 5041 (SCC), you have submitted that the words "in connection with", found in paragraph 95(3)(b), convey only some connection between two related subject matters, not necessarily a direct connection". 1 And on that basis you submit that the manufacturing and processing services described herein should be considered services performed in connection with the sale of goods by Canco. ... They import such meanings as "in relation to", "with reference to" or "in connection with". ...

Whether the work done by NRco could be considered to be "in connection with the exploration for or exploitation of the minerals... ... They import such meanings as "in relation to", "with reference to" or "in connection with". ... Our view is that even if we give to the terms "in connection with" the widest scope possible, the activities performed under the Program could not be considered to be performed "in connection with" or "in respect of" the exploration for or exploitation of the resources. ...

Principal Issues: (a) Is an allowance for the use of a motor vehicle in connection with the duties of an office or employment, based on a per-kilometer amount, a taxable benefit when it is adjusted to a minimum amount per round trip? (b) Is an allowance for the use of a motor vehicle in connection with the duties of an office or employment, based on a per-kilometer amount, a taxable benefit when in the previous month an employee may have received a fixed amount plus a per-kilometer amount allowance? ... Further, the fixed rate allowance for travel within the employment district is taxable since it is not based solely on the number of kilometers for which the vehicle is used in connection with or in the course of the office or employment. ...

The phrase "in connection with or in the course of the office or employment" is not defined in the Act. ... The Concise Canadian Oxford Dictionary does not define the phrase "in connection with or in the course of the office or employment" but does define the phrases "in connection with" and "in the course of". This dictionary defines "in connection with" as "with reference to" and defines "with reference to" as "regarding; as regards". ...

26 May 2010 External T.I. 2009-0342961E5- Computation of the RRIF Minimum Amount Unedited CRA Tags 146.3(1) Principal Issues: How is the minimum amount calculated when the property held in connection with a RRIF has no value? ... You have requested clarification of the calculation of the minimum amount under the RRIF if the fair market value of all the properties held in connection with the RRIF is nil. ... The determination of the fair market value of all properties held in connection with the RRIF is a question of fact. ...

X remains an employee of ACo but also has an opportunity for employment with Canco in Canada in connection with a directional drilling contract secured by Canco with a person unrelated to Aco. ... When the aggregate of the employment duties performed outside Canada in connection with ineligible activities and those performed in Canada in connection with any activity represent more than 10% of all the employment duties, the individual will not meet the "all or substantially all" test. ... X outside Canada in connection with his employment with ACo is 90% or more of all of his employment duties performed for ACo during a qualifying period, Mr. ...