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Our understanding of the facts is as follows: XXXXXXXXXX Our Comments 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. ... We would also like to point out that the employment duties of each particular Indian employee would have to be considered to determine if they were 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. ... Furthermore, we note that your facts state that "the duties of the Indian employees of the Association are in connection with the Association's non-commercial activities carried on for the benefit of Indians who for the most part live on reserve. ...

(2) If an employee does not provide receipts for advances from employers for professional development (PD) travel expenses, should the advances should be reported on these particular employees' T4 slips. (3) If the Employer reimburses an employee for the cost of travel in connection with PD travel, but treats the reimbursement as a non-taxable benefit, can the employee claim the deduction on their personal income tax return? ... In your letter, you raised three questions in relation to travel undertaken by employees of XXXXXXXXXX (the "Employer") in connection with the employees' professional development ("PD"). ... If the Employer reimburses an employee for the cost of travel in connection with PD travel, but treats the reimbursement as a non-taxable benefit, can the employee claim the deduction on their personal income tax return? ...

The Queen, [1983] 2 S.C.R. 428 to be "probably the widest of any expression intended to convey some connection between two related subject matters"; and (3) whether or not a non-resident is liable for tax in Canada is not relevant in determining whether a person must withhold pursuant to subsection 105(1) of the Regulations. Accordingly, any connection between services rendered in Canada and a commission paid by a person to a non-resident may be sufficient to trigger the withholding requirement in subsection 105(1) of the Regulations. For this reason, and because your letter is not clear regarding the details of the connections between the payment of the commission and any services that may be rendered in Canada by you, in your capacity as "paymaster", or any non-resident, it is our view that you should either withhold fifteen per cent from any payment of a commission to any non-resident or attempt to obtain a Treaty-Based Waiver. ...

Reimbursements or awards for legal fees in connection with the collection or establishing a right to income from employment: Reimbursements or awards for legal fees in connection with the collection or establishing a right to income from employment are included in income from an office or employment by virtue of paragraph 6(1)(j) of the Income Tax Act (the "Act"). ... Reimbursements or awards for legal fees in connection with the collection or establishing a right to a retiring allowance: Paragraph 56(1)(l.1) of the Act requires a taxpayer to include in computing income amounts received as an award or reimbursement of legal expenses paid to collect or establish a right to a retiring allowance. ...

Principal Issues: Are legal fees deductible when they are incurred in connection with the issuance of a child support order under the Divorce Act? ... In your letter you have requested clarification of the Department’s position on the deductibility of legal fees incurred in connection with the issuance of a child support order. ... As a further comment, it remains our view that legal fees incurred in connection with spousal maintenance are not deductible because the courts do not have the same discretion with child maintenance as the courts have with spousal maintenance under the Divorce Act. ...

The criteria required to be met in order for the program to qualify as a “qualifying educational program” are set out in subsection 118.6(1) of the Act but excludes any such program “(b) if the program is taken by the student (i) during a period in respect of which the student receives income from an office or employment, and (ii) in connection with, or as part of the duties of, that office or employment.” XXXXXXXXXX, it is our view that the term “in connection with” has a broader meaning than the adjoining phrase contained in (ii) above, “as part of the duties of” and would include any students who are employed in an accounting related field. ... It should also be noted that the requirements of paragraph (b) of the definition of “qualifying educational program”, in subsection 118.6(1) of the Act, also apply to the proposed definition of “specified educational program” in subsection 118.6(1), such that our above comments with respect to the term “in connection with” would also apply to part-time students. ...

The criteria required to be met in order for a program to qualify as a “qualifying educational program” are set out in subsection 118.6(1) of the Act (and explained in IT-515R2), but exclude any such program “(b) if the program is taken by the student (i) during a period in respect of which the student receives income from an office or employment, and (ii) in connection with, or as part of the duties of, that office or employment.” It is our view that the term “in connection with”, in (ii) above, has a broad meaning, such that it would apply to XXXXXXXXXX students who are employed in XXXXXXXXXX related field. ... As a result, the requirements of paragraph (b) of the definition of “qualifying educational program” also apply to the proposed definition of “specified educational program” in subsection 118.6(1), such that our above comments with respect to the term “in connection with” would also apply to part-time students. ...

Paragraph 8308.1(2)(b) applies where the services were rendered in a period throughout which the individual was resident in Canada and the services that were rendered to the employer were primarily rendered in Canada, or in connection with a business carried on by the employer in Canada. Since your situation does not involve services rendered in Canada, and is not in connection with a business carried on by the employer in Canada, paragraph 8308.1(2)(b) does not apply and the employee's pension credit with respect to that employer (and therefore his pension adjustment) is nil. ... A retirement compensation arrangement ("RCA") is defined in subsection 248(1) of the Act to be a plan or arrangement under which contributions are made by an employer or former employer of a taxpayer to another person (a "custodian") in connection with benefits that are to be, or may be, received or enjoyed by any person on, after or in contemplation of any substantial change in the services rendered by the taxpayer, the retirement of the taxpayer, or the loss of an office or employment of the taxpayer. ...

With respect to the co-ordinator, paragraph 8(1)(a) of the Act sets out an exclusion where the taxpayer is employed in the year by the employer "in connection with the performance of any of the duties referred in subparagraph (ii) or similar duties" (subparagraph (ii) refers to an ambulance technician, or a firefighter, or a person who assists in the search or rescue of individuals or in other emergency situations"). ... The Individuals may also visit schools, be available at certain events in case medical services are required, take additional training courses, or attend meetings in connection with the medical services they provide. ... Specifically excluded are employees, who are employed in the year, otherwise than as a volunteer by the employer, in connection with the duties referred to. ...

Loveday File No. 5-8295 Subject:  24(1)  Individual Policyholders' Taxation on Surrenders of Life Insurance Policies We are writing in connection with your memoranda of June 22 and July 31, 1989.  ... Abdulhusein and B.Dodd, October 12, 1989), we are providing you with our comments on  24(1) April 20, 1989 letter and understand that you will reply directly to: 24(1) We apologize for the delay. 24(1)  has requested the Department's views in connection with a worksheet for the calculation of the amount to be included in income under subsection 148(1) of the income Tax Act (the "Act"). 24(1) Item 1) The overall approach being taken by 24(1) (as evidenced by items 1), 2) and 3) collectively), appears to be based somewhat on the method described in the Department's paper on the calculation of the adjusted cost basis ("ACB") for life insurance policies (prepared by G. ... The second component of Item 3), being policy loans after March 31, 1978 was discussed above in connection with item 2) The third component of Item 3), being annual dividends after March  31, 1977 (the date should actually be the MTA), including, termination dividends, and the descriptions thereof contained in 24(1) letter, reflect the appropriate treatment for policy under the Act.  ...