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Technical Interpretation - External

11 August 1995 External T.I. 9509745 - SHAREHOLDER/EMPLOYEE HOUSING LOAN

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

15 November 2018 External T.I. 2018-0762201E5 - Canadian Exploration Expense

Those cases have concluded that for an expense to have been incurred for the purpose of determining the existence, location, extent or quality of an accumulation of petroleum or natural gas, there would have to be a connection between that expense and the actual exploration work (see e.g., Gulf Canada Ltd. v. ...
Technical Interpretation - External

13 May 2003 External T.I. 2003-0013655 - 18(9.1)

If for example, expenses are paid by a parent company on behalf of its subsidiary, in connection with the issuance of shares by its a subsidiary, they are not deductible by the parent company under paragraph 20(1)(e). ...
Technical Interpretation - External

14 May 2003 External T.I. 2003-0001915 - ALLOWANCE PAID TO TRANSPORT

This provision applies where an allowance for travel expenses, other than a motor vehicle allowance, is received by an employee (other than one employed in connection with the selling of property or negotiating of contracts for the employer), and? ...
Technical Interpretation - External

19 September 2003 External T.I. 2003-0034095 - Specified bene of trust & change prin res

As further stated in paragraph 22 of the circular, the CCRA also provides technical interpretations of specific provisions of the Act and accordingly, we offer the following general comments in connection with your request. ...
Technical Interpretation - External

30 December 2003 External T.I. 2003-0053135 - INDIAN EMPLOYMENT ADJACENT TO RESERVE

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 reserve. ...
Technical Interpretation - External

24 March 2004 External T.I. 2003-0032781E5 - Treaty benefits for Irish Investment Undertakings

With respect to who bears the burden of the tax, the Irish Act provides that "an Investment Undertaking shall account for the appropriate tax in connection with a chargeable event in relation to a unitholder... ...
Technical Interpretation - External

23 July 2004 External T.I. 2004-0077351E5 - Indian limited partnership 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 reserve. ...
Technical Interpretation - External

2 March 2005 External T.I. 2004-0108511E5 - Minority discount

Moreover, in connection with file # 911137, Finance was consulted on this very issue and in regards to the Excepting Provisions, Finance confirmed that "fair market value means fair market value and that if it was intended that minority discount be excluded in the calculation of fair market value the legislation would specifically so state. ...
Technical Interpretation - External

7 March 2005 External T.I. 2005-0110651E5 - Employment Income

This value is an amount equal to a prescribed amount per kilometre for operating costs in connection with personal use, paragraph 6(1)(k) of the Act, and a "reasonable standby charge", plus the equivalent to the Goods and Services Tax (GST) on the standby charge, paragraph 6(1)(e) of the Act. ...

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