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Moreover, this position is consistent with previous pronouncements in connection with this issue (see for example, file # 960854, file # 940645, file # 5-5970 and Technical News # 3 page 6). ... Nevertheless, we offer the following general comments in connection with your request which we hope is of assistance to you. ...

Similarly, the OETC enables Canadian employers to reduce their employment costs with respect to foreign contract work, while maintaining the after-tax value of the remuneration their employees receive in connection with such work. ... -The "specified employer" must be carrying on business outside Canada in connection with resource, construction, installation, agricultural or engineering contracts. ...

There is no direct connection between the payor's income and the periodic payments of alimony and maintenance and, therefore, the tax status of the payor's income is not a factor relevant in determining whether alimony and maintenance income received should be exempt. ... In our view, there is no direct connection between the payor's income and the periodic payments of alimony and maintenance and, therefore, the tax status of the payor's income is not a factor relevant in determining whether alimony and maintenance income received should be exempt. ...

In 1994 the individual moved to Ontario in connection with a employment position. ... However, in November 1994, you moved to a location in Ontario in connection with an employment position. ...

In connection with your request, you have enclosed a copy of the standard form of group life insurance policy which you have issued as well as a copy of a draft special terminal illness benefit provision which you intend to add thereto. ... It appears that there may be some confusion but to clarify, the Department may provide general comments in connection with hypothetical situations but such comments are not binding on the Department and may not necessarily apply in the context of a specific situation (and our replies will so state). ...

Revenue Canada's policy on the deduction of bonuses, as discussed at the 1981 Canadian Tax Foundation Conference, is that a bonus will not be considered unreasonable where the recipient is a principal shareholder-manager of the corporation and the corporation's general practice is to distribute its profits to shareholder-managers in the form of bonuses or the company has adopted a policy of declaring bonuses to shareholders to remunerate them for the profits the corporation has earned that are attributable to the special know-how, connections or entrepreneurial skills of the shareholders (1981 Roundtable, question 42). ... If, however, it can be demonstrated that salaries and bonuses paid to persons is to remunerate them for the profits the company has earned that are, in fact, attributable to the special know-how, connections, or entrepreneurial skills of those persons, the test will be considered to have been met. ...

Generally, the deduction in respect of employee travel benefits provided in paragraph 110.7(1)(a) of the Act, offsets the income inclusion in respect of benefits provided by an employer to an employee or the employee's family with respect to trips made for the purpose of obtaining necessary medical services not available locally or with respect to traveling expenses in connection with not more than two other trips per year. ... " In our view, for purposes of paragraph 110.7(1)(a) of the Act, there must be a connection between the actual traveling expenses incurred by a taxpayer or a member of the taxpayer's household and the amounts paid by the taxpayer's employer to defray those costs, in order for the amounts to be "...in respect of travel expenses incurred by the taxpayer... ...

Reasons: The wording of the definition of an RCA in subsection 248(1) of the Act requires that the plan or arrangement be funded in connection with benefits that are to be, or may be, received or enjoyed on, after or in contemplation of a substantial change in services rendered, retirement or loss of employment. ... Our Comments Subject to certain listed exclusions, an RCA is defined in subsection 248(1) of the Act as 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. ...

Generally, the deduction in respect of employee travel benefits provided in paragraph 110.7(1)(a) of the Act, offsets the income inclusion in respect of benefits provided by an employer to an employee or the employee's family with respect to trips made for the purpose of obtaining necessary medical services not available locally or with respect to traveling expenses in connection with not more than two other trips per year. ... " In our view, for purposes of paragraph 110.7(1)(a) of the Act, there must be a connection between the actual traveling expenses incurred by a taxpayer or a member of the taxpayer's household and the amounts paid by the taxpayer's employer to defray those costs, in order for the amounts to be "...in respect of travel expenses incurred by the taxpayer... ...

Application of subsection 126(4) As the Kyrgyz Republic will, under the Contract, only subject XXXXXXXXXX employees to personal tax if those individuals can claim a foreign tax credit, it is our view that subsection 126(4) will be applicable in the situation such that no foreign tax credit will be available for income taxes paid to the Kyrgyz Republic in respect of employment income earned by XXXXXXXXXX employees in connection with the Contract. ... However, see above for the application of the Convention to employment income earned by Canadian residents in the Kyrgyz Republic in connection with the Contract. ...