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Technical Interpretation - External

26 May 2023 External T.I. 2023-0962521E5 - Employment Expenses of a Pilot

The term “eligible tools” is defined in subsection 8(6.1) of the Act as a tool that: a) is acquired by the taxpayer for use in connection with the taxpayer’s employment as a tradesperson, b) has not been used for any purpose before it is acquired by the taxpayer, c) is certified in prescribed form by the taxpayer’s employer to be required to be provided by the taxpayer as a condition of, and for the use in, the taxpayer’s employment as a tradesperson, and d) is not an electronic communication device or electronic data processing equipment (unless it can be used only for the purpose of measuring, locating or calculating). ...
Technical Interpretation - External

31 January 2024 External T.I. 2024-1002821E5 - Employer Crowdfunding Contributions

The broad wording of paragraph 6(1)(a) of the Act means that a taxable benefit may exist where there is any connection between a benefit and the particular office or employment. ...
Technical Interpretation - External

9 May 2024 External T.I. 2022-0958821E5 - T5 filing requirement and impaired debt

Interest payments described in paragraph 201(1)(b) of the Regulations include, among other things, interest (i) on a fully registered bond or debenture; (ii) in respect of money on loan to or on deposit with, or property of any kind placed with, a corporation, association, organization, institution, partnership, or trust; (iii) in respect of an account with an investment dealer or broker; (iv) paid by an insurer in connection with an insurance policy or an annuity contract; or (v) on an amount owning in respect of compensation for property expropriated. ...
Technical Interpretation - External

2 October 2000 External T.I. 2000-0015825 F - ACTIFS AUX FINS DE LA LOI

Bank of Toronto (1924), 56 O.L.R. 318, on indique ce qui suit: "'Assets' is a word that has different meanings in different connections..." ...
Technical Interpretation - External

19 May 2009 External T.I. 2007-0263441E5 - Tax Treaties

For example, if a SOPARFI is created or used in connection with a treaty shopping arrangement where the SOPARFI is in fact only a "resident of convenience", we would not consider it to be a resident of Luxembourg for the purposes of the Treaty. ...
Technical Interpretation - External

11 January 2013 External T.I. 2012-0436771E5 - Sale of a business

., a mortgage prepayment penalty) is incurred in connection with the disposition of a capital property, the cost of the fine or penalty is taken into account under subsection 40(1) for the purposes of calculating any gain or loss on that disposition. ...
Technical Interpretation - External

21 February 2013 External T.I. 2012-0470181E5 - RCA advantage tax rules

An RCA strip occurs where there has been a reduction in value of the property held in connection with the RCA as part of a series of transactions or events one of the main purposes of which was to enable a specified beneficiary (or a person or partnership who does not deal at arm's length with a specified beneficiary) to obtain a benefit in respect of the RCA property or as a result of that reduction, and there has been no related income inclusion. ...
Technical Interpretation - External

12 January 2015 External T.I. 2014-0555071E5 - POD subject to earn-out

In general, the POD of goodwill in connection with a business may be considered as an eligible capital ("EC") amount under subsection 14(1) and may apply to reduce the "cumulative eligible capital" ("CEC") pool pursuant to element E of the CEC definition in subsection 14(5) of the Act. ...
Technical Interpretation - External

14 January 2013 External T.I. 2012-0443561E5 F - Part XIII re: royalties paid for tv program

As such any payments in respect of the copyright of a literary, dramatic, musical or artistic work, including the right in respect of the translation, performance, telecommunication or broadcast of one of the aforementioned works will not be subject to withholding tax unless that payment is for a right in or the use of a motion picture film or a film or video tape for use in connection with television that is to be used or reproduced in Canada. ...
Technical Interpretation - External

4 February 2015 External T.I. 2015-0565741E5 - Canadian-controlled private corporation

A agrees to indemnify Pubco, its directors and its employees (collectively, the "Indemnified Parties") in respect of claims and liabilities arising in connection with Pubco having served as trustee of the A Trust, including claims and liabilities of the A Trust for which any of the Indemnified Parties may be or become liable. 8. ...

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