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Technical Interpretation - External
4 April 2024 External T.I. 2023-0959911E5 - Indian Act tax exemption and Employment Income
The duties of employment are in connection with the employer’s non-commercial activities carried on exclusively for the benefit of First Nations individuals who for the most part live on reserves. ...
Technical Interpretation - External
24 September 2024 External T.I. 2023-0972671E5 - Indian Act tax exemption and Employment Income
The duties of employment are in connection with the employer’s non-commercial activities carried on exclusively for the benefit of First Nations individuals who for the most part live on reserves. ...
Technical Interpretation - External
8 October 1993 External T.I. 3M09520 - APFF 1993
3) If a debt of this kind is assumed by a taxpayer in connection with the transfer of the assets for which the loan was contracted, will the Department allow a deduction under paragraph 20(1)(hh) of the Act to the original borrower on the transfer of the business or to the purchaser when it repays the loan? ... Where a debt is transferred by a taxpayer in connection with the transfer of the assets for which the loan was contracted, the taxpayer would not be eligible for a deduction since there is no repayment of the debt. ... In this connection, the June 1992 Explanatory Notes issued by the Department of Finance accompanying Bill C-92 (now enacted) are quite clear. ...
Technical Interpretation - External
9 March 2007 External T.I. 2007-0225661E5 - Renewable Energy Property
To qualify under the Program, applicants must ensure that the project meets certain requirements, must be willing to make necessary investments in their facilities and must bear the costs of connection to the local distribution system and metering, as well as certain ongoing costs of operation and maintenance. ...
Technical Interpretation - External
11 March 1999 External T.I. 9901605 - SPECIAL WORK SITE
(vii) reasonable allowances for travelling expenses (other than allowances for the use of a motor vehicle) received by an employee (other than an employee employed in connection with the selling of property or the negotiating of contracts for the employer) from the employer for travelling away from (A) the municipality where the employer's establishment at which the employee ordinarily worked or to which the employee ordinarily reported was located, and (B) the metropolitan area, if there is one, where that establishment was located, in the performance of the duties of the employee’s office or employment,...” ...
Technical Interpretation - External
10 October 1990 External T.I. 90M10185 F - Tax Penalty Structure in Canada
Judicial penalties, which are imposed only in connection with a criminal proceeding, involve either a fine, imprisonment, or both, depending on the criminal offence. 44. ...
Technical Interpretation - External
15 December 2000 External T.I. 2000-0029125 F - POMPIER VOLONTAIRE
Regular employment Proposed subparagraph 81(4)(b)(ii) stipulates that an individual cannot take advantage of the $1,000 exemption if the duties that he or she performs in connection with his or her regular employment for the same municipality, other than as a volunteer, are similar to the duties performed as a volunteer. ...
Technical Interpretation - External
21 July 2003 External T.I. 2002-017676A - In Trust Accounts
It would be sufficient in this case to say that there is nothing in the transaction which necessarily implies that the testatrix (intending only a benefit to take effect after here death, and in connection with her will) meant to place this disposition of her property out of her control in her lifetime. ...
Technical Interpretation - External
16 August 2011 External T.I. 2009-0342101E5 - Operation of Ships
If, in fact, that cargo handling operation had developed to a stage where it was beyond any reasonable requirements of the company's own ships, it would seem appropriate to treat it as a separate business and, in the context of the question at hand, to exclude those revenues arising in connection with cargo services provided to the other ship owners. ...
Technical Interpretation - External
27 September 2000 External T.I. 2000-EM20425 - 2000 CTF Paper - Judicial & Adm Developments
I understand that the United States, when faced with the same issue, made legislative amendments to codify restrictions on the deductibility of payments based on public policy grounds, such as punitive damages, bribes, fines and penalties, and expenditures in connection with the illegal sale of controlled substances. ...