Search - connection

Yes, if the amounts are paid by the employer (or a by a person with whom the employer does not deal at arm's length) to another person in connection with benefits that are to be received on the loss of an office or employment of the taxpayer. ... In this context, the words "in respect of" have been held by the Courts to imply a connection between the loss of employment and the receipt, where the primary purpose of the receipt was compensation for the loss of employment. ... Accordingly, where an employer pays retiring allowance amounts to a third party (e.g. a trust) in connection with benefits that are to be paid to an employee for the loss of an office or employment by the employee, such an arrangement would constitute an RCA as defined in subsection 248(1) of the Act. ...

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. ... This exception is very narrow and is available only where there is no connection or link to the employment relationship. ...

The Tax Court of Canada concluded that the non-resident shareholders had de jure control of Alias because they held the simple majority of voting shares, notwithstanding that there was no common connection between them. ... On the issue of de jure control, the Federal Court of Appeal equated the phrase "control by one or more persons" in the CCPC definition with the phrase "control by a person or group of persons", and, based on prior case law, agreed with Silicon Graphics that in order for a group of persons to be in a position to exercise de jure control, a common connection must exist between the shareholders. As there was no evidence of a common connection, the Federal Court of Appeal overturned the Tax Court of Canada's decision. ...

Any income or capital gain earned in connection with the SIPP would be generally taxable in Canada on a current, annual basis. ... However, to the extent the individual would be subject to tax in the UK in connection with the SIPP, a foreign tax credit may be available. ... To the extent a taxpayer would be subject to tax in the UK in connection with the plan, a foreign tax credit may be available. ...

In particular, you have asked us whether the employment income earned by the Employees in connection with the Employer’s non-commercial activities performed exclusively for the benefit of Indians who live both on and off reserve is exempt from tax under section 87 of the Indian Act regardless of where their office is located. ... Furthermore, the duties of employment must be in connection with the employer’s non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserve. ... Additionally, the employee’s duties of employment must be 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. ...

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. ... The connection to reserves in Guideline 4 is established through the employment duties benefiting First Nations individuals who for the most part live on reserves. Therefore, if the population benefiting from the employer’s non-commercial activities is not comprised of a majority of First Nations individuals who live on reserves, this connection would not exist, and Guideline 4 would not apply. ...

We apologize for the delay in responding to your letter and are writing to advise you that we have undertaken a study of several issues which have arisen in connection with that provision. ...

If a corporation can show that it was established or incorporated principally in connection with, or to administer or provide benefits under one or more superannuation, pension or retirement funds or plans or any funds or plans established to provide employee benefits, it will qualify for a certificate of exemption provided it can also satisfactorily establish that it meets the requirements of paragraphs 212(14)(a) and (b).  21(1)(b) for Director Reorganization and Non-Resident DivisionRulings DirectorateLegislative and IntergovernmentalAffairs Branch ...

Subparagraph 146(2)(c.4)(ii) of the Act specifically exempts payments made into the plan by the issuer from being an advantage extended to the annuitant, and, it is our general position that amounts paid into the plan in connection with the plan assets are not considered to be advantages. ...

In answer to question 42 of the Round Table session, it was stated that: In general, the reasonableness of salaries and bonuses paid to principal shareholder-managers of a corporation would not be challenged when: a) the general practice of the corporation is to distribute the profits of the company to its shareholder-managers in the form of bonuses or additional salaries; or b) the company has adopted a policy of declaring bonuses to the shareholders to remunerate them for the profits the company has earned that are attributable to special know-how, connections or entrepreneurial skills of the shareholders. ... In general, the Department will not challenge the reasonableness of salaries and bonuses paid to the principal shareholders-managers of a corporation when (a) the general practice of the corporation is to distribute the profits of the company to its shareholders-managers in the form of bonuses or additional salaries; or (b) the company has adopted a policy of declaring bonuses to the shareholders 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 the shareholders. ...