Search - connection

Although the employee's residence would not be a factor which connects the Indian's employment to the reserve, it is appropriate, under the circumstances laid out in Guideline 4, to recognize a connection since the employee is working for the benefit of Indians on reserve. However, if the population served by the organization was not comprised almost entirely of Indians who live on reserve, this latter connection would not exist. In addition, to determine whether Guideline 4 applies, the employment duties of each particular Indian employee of the Council would have to be considered to establish if they were in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserves. ...

Eisner August 15, 1995 Dear Sir: Re: Personal Use of Vehicle This is in reply to your letter of January 23, 1995 in which you requested our views on whether certain travel is of a personal nature in connection with the determination of vehicle benefits. ... Nonetheless, where the individual is provided with a work location where, in connection with his or her employment duties, reports are filed, instructions or employment information is received, or other employment duties are involved, and the employee reports to the location on a basis such as every second or third day or every week or so, that work location is considered to be the employee's regular place of work. ... It is also our view that travel from (a) the individual's residence to a location to perform employment duties (e.g. a business appointment or meeting) and the return trip back to the residence, and (b) the regular place of employment to a location in connection with employment duties and then to the individual's residence, is of a business nature. ...

3.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". ... " In our view, when you consider the words "purchase and sale" and the type of debt that is being referred to in the words "in connection with", one would have to conclude that it would be a miscellaneous type of debt such as brokerage fees or other incidental amounts that could relate either to the purchase or the sale. ...

Although the employee's residence would not be a factor which connects the Indian's employment to the reserve, it is appropriate, under the circumstances laid out in Guideline 4, to recognize a connection since the employee is working for the benefit of Indians on reserve. However, if the population served by the organization was not comprised almost entirely of Indians who live on reserve, this latter connection would not exist. In addition, to determine whether Guideline 4 applies to a particular Indian employee, the employment duties of the Indian employee would also have to be considered, in order to establish whether they are in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserves. ...

We cannot conclusively establish whether XXXXXXXXXX provides services, and XXXXXXXXXX duties are in connection, to Indians who for the most part live on reserve. ... However, if the population served by the organization was not comprised almost entirely of Indians who live on reserve, this latter connection would not exist. ... XXXXXXXXXX duties of employment must be in connection with the employer's non-commercial activities. ...

In determining whether Guideline 4 applies to a particular Indian employee, the employment duties of the Indian employee would also have to be considered, in order to determine whether they are in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserves. ... Although the employee's residence would not be a factor which connects the Indian's employment to the reserve, it is appropriate, under the circumstances laid out in Guideline 4, to recognize a connection since the employee is working for the benefit of Indians on reserve. However, if the population served by the organization was not comprised almost entirely of Indians who live on reserve, this latter connection would not exist. ...

We cannot conclusively establish whether XXXXXXXXXX provides services, and XXXXXXXXXX duties are in connection, to Indians who for the most part live on reserve. ... However, if the population served by the organization was not comprised almost entirely of Indians who live on reserve, this latter connection would not exist. ... XXXXXXXXXX duties of employment must be in connection with the employer's non-commercial activities. ...

In connection with your concern, we also wish to acknowledge that in our discussion with Mr. ... In connection with the above comments, it would also be useful to compare the leasing arrangement to a typical leasing arrangement of an entity that leases automobiles on a day to day basis. ... " In connection with the comments in (b) above, the facts that Holdco has no employees and that there is no written lease agreement suggest that Holdco may have limited responsibilities with respect to the lease arrangement. ...

However, if the population served by the organization is not comprised almost entirely of Indians who live on reserve, this latter connection would not exist. ... The employee's duties of employment must be in connection with the employer's non-commercial activities. To determine whether Guideline 4 applies to a particular Indian employee, the employment duties of the Indian employee would also have to be considered, in order to establish whether they are in connection with the employer's non-commercial activities. ...

Position: (1) Yes, assuming that throughout that "qualifying period" the employee performed all or substantially all (that is, at least 90%) the duties of his or her employment: (i) outside Canada; and (ii) in connection with a contract under which Canco carried on business in the U.S. with respect to a "qualifying activity". ... During a period of absence from the work location, an employee may perform duties of employment in Canada and still remain eligible for the OETC provided that throughout the "qualifying period" substantially all (i.e., at least 90%) of the employment duties are performed outside Canada and in connection with a contract under which the employer carried on business outside Canada with respect to a "qualifying activity". ... It appears that this substantially all test would be met if the employee were to work at a New York state work site for five months in connection with a contract under which Canco carried on business outside Canada with respect to a "qualifying activity", return to work at Canco's office in Canada for a week and then return to the New York state work site to work on that contract for the remainder of the year. ...