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Technical Interpretation - External

10 November 1997 External T.I. 9711175 - FOREIGN AFFILIATES - INVESTMENT BUSINESS

FSC's business consists solely of marketing and the collection of receivables performed in connection with the sale by Usco of its products to customers residing outside the United States including persons resident in Canada who deal at arm's length with Canco. 4)FSC has International Business Corporation status in Barbados and is ineligible for any tax benefit available under the Canada- Barbados Income Tax Convention (the "Barbados Convention") by virtue of Article XXX(3) thereof. ...
Technical Interpretation - External

29 September 1997 External T.I. 9720175 - INDIAN ACT EXEMPTION - GUIDELINES 3 AND 4

Please note that Guideline 4 requires a) that the employer is resident on a reserve; b) that the employer is an Indian band which has a reserve, or a tribal council representing one or more Indian bands which have reserves, or an Indian organization controlled by one or more such bands or tribal councils, if the organization is dedicated exclusively to the social, cultural, educational, or economic development of Indians who for the most part live on reserves; and c) that the duties of employment 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. ...
Technical Interpretation - External

29 May 1998 External T.I. 9811105 - INDIAN EMPLOYMENT INCOME & GUIDELINE 4

Please note that Guideline 4 requires: a) that the employer is resident on a reserve; b) that the employer is an Indian band which has a reserve, or a tribal council representing one or more Indian bands which have reserves, or an Indian organization controlled by one or more such bands or tribal councils, if the organization is dedicated exclusively to the social, cultural, educational, or economic development of Indians who for the most part live on reserves; and c) that the duties of the employment 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. ...
Technical Interpretation - External

6 July 1998 External T.I. 9709445 F - SENS DE L'EXPRESSION "RÉGION MÉTROPOLITAINE"

For example, there are no common infrastructures, municipal services such as streets, water, fire or police protection, and there is no political connection. ...
Technical Interpretation - External

8 October 1998 External T.I. 9733435 - CHILD SUPPORT

In connection with this situation, it is noted that, pursuant to section 8 of the Guidelines, the court order sets out a net amount which is the difference between the amount that Individual D is required to pay to Individual C under the Guidelines with respect to Child 1 and the amount Individual C would pay to Individual D under the Guidelines with respect to Child 2. ...
Technical Interpretation - External

15 December 1998 External T.I. 9821955 - PRINCIPAL RESIDENCE

Generally, an individual’s use of land in excess of 1/2 hectare in connection with a particular lifestyle does not, in itself, mean that the excess land is necessary for the use and enjoyment of the housing unit as a residence. ...
Technical Interpretation - External

14 December 1998 External T.I. 9824705 - CHILD SUPPORT

In connection with this concern you have asked us whether the fact that the Second Order sets out an interest rate in respect of the Arrears changes the nature of the payments received by the Recipient in respect of the Arrears. ...
Technical Interpretation - External

2 November 2018 External T.I. 2018-0771861E5 - TOSI: Second generation income

Furthermore, paragraph 120.4(1.1)(d) states that: (d) for greater certainty, an amount derived directly or indirectly from a business includes (i) an amount that (A) is derived from the provision of property or services to, or in support of, the business, or (B) arises in connection with the ownership or disposition of an interest in the person or partnership carrying on the business, and (ii) an amount derived from an amount described in this paragraph. ...
Technical Interpretation - External

23 June 1994 External T.I. 9403465 - SEMINAR EXPENSES

" "Claims in connection with a training course held outside the territorial limits of a sponsoring professional organization or business association are generally considered to be unreasonable to the extent that they exceed what they would have been had that course been held within such territorial limits. ...
Technical Interpretation - External

28 October 1994 External T.I. 942445A - HEALTH AND WELFARE TRUSTS

In connection with (c) and (d) above, we require that the trust document contain a clause that no property of the trust, whether such property is acquired from the capital or income of the trust, shall be invested in the shares, notes, bonds, debentures or similar indebtedness issued by: (a) the employer, (b) a person who does not deal at arm's length with the employer or (c) a person who is a member of a group of persons not dealing at arm's length with the employer, nor shall any such property of the trust be invested in property which is or will be used directly or indirectly, solely or otherwise, by the employer or any person who does not deal at arm's length with the employer or who is a member of a group of persons not dealing at arm's length with the employer. ...

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