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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. ...
Technical Interpretation - External
15 November 1994 External T.I. 9415225 - LOAN TO A CHARITY
Paragraphs 149.1(3)(d) and 149.1(4)(d) exclude debts for current operating expenses, debts incurred in connection with the purchase and sale of investments and debts incurred in the course of administering charitable activities. ...
Technical Interpretation - External
24 January 1995 External T.I. 9428115 - TAXABILITY OF MEAL ALLOWANCES AND REIMBURSEMENTS
Where the meals or allowances are provided in connection with a requirement to work overtime, the Department has established the criteria for the non-inclusion of the benefit in the employee's income. ...
Technical Interpretation - External
22 April 1996 External T.I. 9600645 F - ALLOCATION DE FIN DE CARRIERE
Younge-Eglinton Building Ltd, 74 DTC 6181, l'expression «in the course of» est défini comme signifiant «in connection with», or «incidental to» or «arising from». ...
Technical Interpretation - External
22 October 1996 External T.I. 9606175 - FISCAL PERIOD OF PARTNERSHIP
In connection with whether the rental of real property generates income from a business or a property we would refer you to Interpretation Bulletin IT-434R. ...
Technical Interpretation - External
7 July 1993 External T.I. 9306395 F - Loan to Purchase Principal Residence
In connection with these comments, we also note that subsection 80.4(3) provides that subsections 80.4(1) and (2) of the Act do not apply in respect of any loan or debt that was included in computing the income of a person under Part I of the Act. ...
Technical Interpretation - External
31 August 1993 External T.I. 9311685 F - Health and Welfare Trusts - Small Businesses
In connection with the above comments, paragraph 4 of IT-85R2 indicates that if one of the plans administered by a trust was considered not to be (a) a private health services plan, (b) a group term life insurance policy or (c) a wage loss replacement that qualifies as a group sickness or accident insurance plan, the combined plan is given employee benefit plan or employee trust treatment in respect of the timing and amounts of both employer's expense deductions and the employees' receipt of benefits under the plan. ...
Technical Interpretation - External
14 March 1995 External T.I. 9428745 - TUITION- XXXXXXXXXX
An exception to this general rule is available to taxpayers employed in connection with the selling of property or negotiating of contracts for his or her employer and who is remunerated in whole or part by commissions or other similar amounts (see paragraph 8 of Interpretation Bulletin IT-357R2 for additional details). ...
Technical Interpretation - External
20 October 1995 External T.I. 9515555 - ALBERTA IRRIGATION DISTRICTS
A mileage or per kilometre allowance would be included in the calculation of income as a "mileage or other travelling allowance" referred to in paragraph 3 of Interpretation Bulletin IT-292 if the allowance 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. ...
Technical Interpretation - External
10 April 2003 External T.I. 2002-0147295 - COMPOUND INTEREST
As we stated above in connection with a disposition of land, we would also consider it unusual for a creditor to permit a disposition of a building before it has been paid the compound interest that had accrued. ...