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Our position is: (a) The phrase "for use in connection with television" as used paragraph 212(5)(b) of the Act is not limited to television broadcasting. The only restriction on the application of paragraph 212(5)(b) is where a film, videotape or other means of reproduction for use in connection with television is solely in connection with and as a part of a news program produced in Canada. ... Royalties in respect of the production or reproduction of motion pictures or videotapes which are not for private (home) use, including but not limited to those used in connection with television broadcasting, are not exempt. ...

Principal Issues: Whether debts "incurred in connection with the purchase and sale of investments... ... Our Comments Paragraph 149.1(4)(d) of the Income Tax Act refers to a debt "incurred in connection with the purchase and sale of investments... ... In particular, in our view, loans obtained or debts incurred for the purpose of permitting a public or private foundation to purchase investments are not debts "incurred in connection with the purchase and sale of investments". ...

To function as a cogeneration system, each micro-turbine requires a connection to the gas supply, electrical, primary heating and control systems of the greenhouse. ... With regard to the natural gas connection, the gas main to the greenhouse does not only serve the micro-turbine units, and the system boundary for the gas connection is where the gas enters the micro-turbine units. Therefore, in our view, none of the costs of the gas supply connections are eligible for Class 43.1. ...

Principal Issues: Interpretation of phrase "restructuring of debt in connection with a proceeding commenced in a court in Canada before February 22, 1994" as that phrase is used in the draft legislation to amend section 80. Position TAKEN: Restructuring of debt can occur subsequent to court proceeding provided it is in connection with that court proceeding which commenced prior to Feb. 22, 1994. ... Any negotiated settlement and restructuring, that is in connection with that court proceeding, could occur subsequent to February 22, 1994. ...

Principal Issues: Are minimum amounts that are paid to employees, for the use of a motor vehicle in connection with the duties of an office or employment, taxable benefits where the amount is not based solely upon a per-kilometer calculation? ... Subparagraph 6(1)(b)(x) of the Act deems the allowance not to be reasonable if the measurement of the use of the vehicle is not based solely on the number of kilometres for which the vehicle is used in connection with or in the course of the office or employment. Where a minimum amount is paid for a round trip that is not based solely on kilometers used, it would have to be determined whether this amount (even when it is a nominal amount) is paid to employees to compensate them for the actual expenses incurred in using their motor vehicle in connection with the duties of the office or employment for any given day. ...

Specifically, you requested our views whether the loan described above would be considered, for purposes of paragraph 149(4)(d) of the Act, a debt incurred in connection with the purchase and sale of investments. ... In any specific case the determination as to whether debts are incurred "in connection with" the purchase and sale of investments is a question of fact to be determined on the basis of all the details in that case. In our view the words "in connection with" contemplate a direct relationship between the incurring of the debt and the purchase and sale of investments. ...

Position: It depends on the strength of the connection between the employment insurance benefits and the fishing income. ... The trial judge in Williams noted that the connection between the benefits and the qualifying employment was strong because the benefits are based on premiums arising from the previous employment. ... The Queen, 2011 DTC 1314), the courts held that given the connections between the fishing income and the reserve, the fishing income was situated on the reserve and therefore exempt from income tax, despite the delivery of fish off the reserve. ...

Reasons: The payment is for the use of the copyrighted photograph and not on account or in lieu of payment of, or in satisfaction of, payment for a right in, or to the use of, a motion picture film, or a film, video tape or other means of reproduction for use in connection with television. ... This letter will address the circumstances in which the Payments are for the use of the photographs in connection with television in Canada (for example in a backdrop to a film clip used in a television program that is to be used or reproduced in Canada). ... " For ease of reference, hereafter the phrase "a film, video tape or other means of reproduction for use in connection with television" as they appear in 212(5)(b) above, will be referred to as Television Product. ...

Dependent on whether the extension or renewal period is considered to be in connection with the original commitment made by the employer. 3. ... The phase-out rules will not apply with respect to qualifying foreign employment income earned by an employee in connection with a project or activity to which the employee's employer had committed in writing before March 29, 2012. ... Whether the QFEI is earned in connection with a contract that was committed to in writing before March 29, 2012, is one of fact that can only be determined on a case-by-case basis. ...

Principal Issues: Whether the ECE of a son who acquires eligible capital property from a corporation controlled by his parents would be subject to a reduction under subsection 14(3) of the Act based on an earlier claim for capital gains exemption made by the parents in connection with the disposition the corporation. ... Reasons: The ECE reduction under ss 14(3) of the Act takes into account capital gains exemption claimed by a person not dealing at arm's length in connection with an earlier disposition by that person to a person not dealing at arm's length. ... This is because the ECE reduction under subsection 14(3) of the Act takes into account any capital gains exemption claimed by another person with whom the transferee (in this case, the second transferee) was not dealing at arm's in connection with an earlier disposition of the same eligible capital property. ...