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Under paragraph 146.3(2)(e) of the Act, the terms of the RRIF arrangement must provide the RRIF annuitant with the right to direct the carrier to transfer the property held in connection with the fund to another carrier. ... Generally, the minimum amount is computed by multiplying a prescribed factor by the total fair market value of properties held in connection with the RRIF arrangement at the beginning of the year. ...

However, subparagraph 6(1)(b)(x) of the Act provides that, for purposes of these subparagraphs, an allowance received in a taxation year by a taxpayer for the use of a motor vehicle in connection with or in the course of the taxpayer's office or employment is deemed not to be a reasonable allowance if the measurement of the use of the vehicle for the purpose of the allowance is not based solely on the number of kilometres for which the vehicle is used in connection with or in the course of the office or employment. ...

In our view, expenses incurred by such an employee in connection with the legal deposit of copies with the National Library of Canada would be eligible under this provision. ... Where the expenses are not incurred in connection with earning income from a business or property, or from employment, as discussed above, they would not be deductible for income tax purposes. ...

In this regard, you have referred to the 1998 version of the guide entitled “Rental Income,” which includes comments on the circumstances in which vehicle expenses can be claimed in respect of rental properties and makes reference to the guide entitled “Business and Professional Income,” in connection with the calculation of vehicle expenses. ... However, there are some limitations in connection with vehicle expenses which may relate to the cost of a vehicle, interest and leasing costs. ...

As explained in Interpretation Bulletin IT-153R3, the limitations on the deduction of carrying charges provided for in paragraphs 18(2)(e) and (f) do not apply in connection with land that can reasonably be considered to have been used in the course of a business other than a land development business carried on in the year by the taxpayer, by virtue of paragraph 18(2)(c) of the Act, or held primarily for the purpose of gaining or producing income of the taxpayer from the land for the year, by virtue of paragraph 18(2)(d) of the Act. The following comments apply in connection with land not referred to in paragraphs 18(2)(c) and (d) of the Act and may not be relevant to your fact situation. ...

Subparagraph 5907(1)(d)(vi.1) of the Regulations provides for an adjustment to the exempt surplus account of a foreign affiliate in respect of an ACT credit received by it in connection with a dividend from another affiliate that is added to the exempt surplus of the recipient pursuant to subparagraph 5907(1)(d)(vi) of the Regulations and subsection 5907(7.1) of the Regulations provides for adjustments to the surplus accounts of a U.K. foreign affiliate in respect of an ACT credit received by a Canadian company in connection with a dividend paid to the Canadian company by the U.K. foreign affiliate. ...

They are not reimbursed, in whole or in part, by the corporation for the expenses they might incur with respect to the operation of their vehicles in connection with their corporate employment. ... In addition to the above, the corporation pays both husband and wife a "per kilometre" allowance for the use of their respective vehicles in connection with their employment duties with the corporation. ...

Thus, a settlement amount received in connection with a loss of employment may fall within the definition of a retiring allowance. The Canadian courts have set out two questions to determine whether a connection exists for purposes of a retiring allowance: But for the loss of employment would the amount have been received? ... Based on the limited facts provided, it appears that the Payment was received in connection with a loss of employment, therefore it would likely be a retiring allowance and included in the former employee's income under paragraph 56(1)(a)(ii) of the Act. ...

Reasons: Based on the Byram decision, where a clear connection between the shareholder and the corporation's dividend icnome can be demonstrated, subparagraph 40(2)(g)(ii) should not be applied to deny the capital loss. It is a question of fact whether such a connection exists. 2006-017211 XXXXXXXXXX G. ... Where a loan is made for the purpose of earning income through the payment of dividends, this connection is sufficient to satisfy the purpose requirement of subparagraph 40(2)(g)(ii). ...

The limited weight that the on reserve location of the cooperative would otherwise carry, as a connecting factor, will not be recognized if it can reasonably be considered that one of the main purposes for the establishment of the cooperative is to serve as a connection between the fishermen's business income and a reserve, by acting as an intermediary between the fishermen and the actual fish buyers who are located off reserve. ... Furthermore, where an arrangement creates an artificial connection between business income and a reserve, the arrangement will carry no weight as a connecting factor. ... Finally, we would also like to note that, in our view, where an arrangement creates an artificial connection between business income and a reserve, the arrangement will carry no weight as a connecting factor. ...