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Technical Interpretation - External
19 August 2010 External T.I. 2010-0371151E5 - Grants and Awards
Given the purpose of a payment under the XXXXXXXXXX (and provided the amount is not received in connection with employment), we are of the view that the payment could be viewed as scholarship income of the recipient. It should be noted that a student may be able to claim a scholarship exemption under subsection 56(3) for the full amount of a scholarship provided it was received in connection with the student's enrolment in an educational program that entitles the student to the Education Tax Credit. ...
Technical Interpretation - External
29 May 2009 External T.I. 2009-0313571E5 - Eligible expenditures - home renovation tax credit
You have described three scenarios for hot tub purchases: The 'plug in product' type of hot tub comes with the cord connected and ready to use, without the need of a permanent electrical connection. ... The customer is completing a back yard renovation that includes new decking, site preparation (as described immediately above) for a hot tub as well as the electrical connection for the hot tub. ...
Technical Interpretation - External
19 June 2009 External T.I. 2009-0313051E5 - Prescribed Prize
They import such meanings as "in relation to", "with reference to" or "in connection with". The phrase "in respect of" is probably the widest of any expression intended to convey some connection between two related subject matters. ...
Technical Interpretation - External
10 March 2010 External T.I. 2009-0349531E5 - Northern residents deduction
., they must have some close connection to each other) so that it is reasonable to conclude that such persons are members of the taxpayer's household. ... " It is our view that "a member of a taxpayer's household" for the purposes of subsection 110.7(1)(a) of the Act should only include individuals who are living together as a family unit (i.e., the individuals must have some close connection with one another) in the same self-contained domestic establishment. ...
Technical Interpretation - External
6 October 2008 External T.I. 2008-0290421E5 - Education Credit- Reimbursement
For years prior to 2004, the former definition of "qualifying educational program" in the Income Tax Act (the "Act") excluded any program taken by a 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. ... This means that provided all other requirements are met, a course or program taken by an individual in connection with his or her employment and during which time the individual received income from that employment is a "qualifying educational program" eligible for the education tax credit. ...
Technical Interpretation - External
26 November 2008 External T.I. 2008-0280801E5 - Deductibility of Settlement and Related Legal Fees
26 November 2008 External T.I. 2008-0280801E5- Deductibility of Settlement and Related Legal Fees Unedited CRA Tags 9 18(1)(a) Principal Issues: Whether settlement payments made by a farmer for property damage and personal injury suffered in connection with a tractor-vehicle collision are deductible from business income. ... You asked for our comments regarding whether a settlement payment made by a farmer for property damage and personal injury suffered in connection with a tractor-vehicle collision is a deductible business expense. ...
Technical Interpretation - External
11 February 2008 External T.I. 2007-0248181E5 - Scholarships
Subsection 56(3) provides an exemption for scholarship, fellowship or bursary amounts received by an individual in connection with the individual's enrolment at a designated educational institution (e.g., a university or college) in a program in respect of which the individual may claim the education tax credit (ETC). ... Subsection 56(3) was also recently amended by the above-mentioned Bill C-28 to provide an annual exemption for a scholarship or bursary received by an individual in connection with the individual's enrolment in an elementary or secondary school. ...
Technical Interpretation - External
6 March 2006 External T.I. 2004-0103391E5 - Repayment of salary
Reasons: Paragraph 8(1)(f) of the Act provides for a deduction from income, "where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for the taxpayer's employer, and....amounts expended by the taxpayer in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts referred to in subparagraph (iii) and received by the taxpayer in the year) to the extent that those amounts were not... ... Our Comments Paragraph 8(1)(f) of the Act provides for a deduction from income, "where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for the taxpayer's employer, and....amounts expended by the taxpayer in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts referred to in subparagraph (iii) and received by the taxpayer in the year) to the extent that those amounts were not... ...
Technical Interpretation - External
13 March 1998 External T.I. 9727585 - INCOME FROM RRIF OR MUTUAL FUND TAXABLE?
Principal Issues: Enquiry in connection with the taxability of amounts received from a RRIF or a mutual fund. ... Nevertheless, we offer the following general comments in connection with your request which we hope is of assistance to you. ...
Technical Interpretation - External
24 June 1998 External T.I. 9808135 - NON-ARM'S LENGTH SECURITIES TRANSACTIONS
Reasons FOR POSITION TAKEN: Interpretation of the Law and position adopted is consistent with previous pronouncements in connection with this matter (March 25, 1998- file # 5-972840, April 24, 1995- file # 5-942771, August 5, 1993 file # 5-931919, November 14 1989 file # 74376A). ... Nevertheless, we offer the following general comments in connection with your request which we hope is of assistance to you. ...