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Technical Interpretation - External
18 September 2008 External T.I. 2008-0274361E5 - Employee Living Allowances
In connection with the above, while XXXXXXXXXX is in a prescribed intermediate zone, whether or not an Employee working at the Facility meets all the particular conditions of paragraph 110.7(1)(b) of the Act for a particular taxation year can only be determined after a review of all of the relevant facts. ...
Technical Interpretation - External
20 November 2008 External T.I. 2008-0296181E5 - renewable Energy Projects - Tidal Energy
Examples of the types of expenses that are eligible for CRCE are described in subsection 1219(1) of the Regulations and include: (a) expenses incurred for the purposes of making a service connection to the project for the transmission of electricity to a purchaser of the electricity, to the extent the expense was not incurred to acquire property; (b) expenses incurred for the construction of a temporary access road to the project site; (c) expenses incurred for a right of access to the project site before the earliest time at which a property described in Class 43.1 or 43.2 is used in the project for the purpose of earning income; (d) expenses incurred for clearing land to the extent necessary to complete the project; and (e) expenses incurred for process engineering for the project, including (i) collection and analysis of site data, (ii) calculation of energy, mass, water or air balances, (iii) simulation and analysis of performance and cost of process design options, and (iv) selection of the optimum process design. ...
Technical Interpretation - External
13 December 2007 External T.I. 2007-0227511E5 - Workspace in Home
In order to deduct home office expenses under the authority of paragraph 8(1)(f) of the Act, a taxpayer must be employed in connection with the selling of property or the negotiation of contracts for his or her employer, must be required under the contract of employment to pay his or her own expenses and must be remunerated in whole or in part by commissions referenced by volume of sales. ...
Technical Interpretation - External
21 October 1998 External T.I. E9813775 - INDIAN ACT EXEMPTION - EMPLOYMENT INCOME
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
15 December 1998 External T.I. E9821495 - FOREIGN AFFILIATES - FOREIGN TAX / LLCS
Position: Various Reasons: 982149 XXXXXXXXXX Olli Laurikainen (613) 957-2116 Attention: XXXXXXXXXX December 15, 1998 Dear Sirs: Re: United States Limited Liability Companies This is in reply to your letter dated August 6, 1998 requesting our views in connection with certain hypothetical foreign affiliate structures involving United States Limited Liability Companies (“LLCs”). ...
Technical Interpretation - External
26 May 1998 External T.I. 9807195 - PERSONAL USE OF EMPLOYER VEHICLES
First, there is the benefit associated with the operating costs related to the use of the automobile in the year that was not in connection with office or employment. ...
Technical Interpretation - External
29 June 1998 External T.I. 9805875 - INDIAN STATUS INCOME
It also requires 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 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
21 October 1998 External T.I. 9813775 - INDIAN ACT EXEMPTION - EMPLOYMENT INCOME
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
15 December 1998 External T.I. 9821495 - FOREIGN AFFILIATES - FOREIGN TAX / LLCS
Position: Various Reasons: 982149 XXXXXXXXXX Olli Laurikainen (613) 957-2116 Attention: XXXXXXXXXX December 15, 1998 Dear Sirs: Re: United States Limited Liability Companies This is in reply to your letter dated August 6, 1998 requesting our views in connection with certain hypothetical foreign affiliate structures involving United States Limited Liability Companies (“LLCs”). ...
Technical Interpretation - External
17 February 1995 External T.I. 9400545 - RESIDENCE & SOURCE DEDUCTIONS (HAA7576-1)
Leung (613) 957-2115 Attention: XXXXXXXXXX February 17, 1995 Dear Sirs: Re: Paragraph 250(1)(a) of the Income Tax Act (the "Act") and Articles IV and XV of the Canada-United States Income Tax Convention (the "Convention") We are writing in response to your letter of January 3, 1994 in which you requested our views on certain matters in connection with paragraph 250(1)(a) of the Act and Articles IV and XV of the Convention. ...