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29 February 2016 External T.I. 2015-0614151E5- Deductibility of Actuarial Fees CRA Tags 18(1)(a) 18(1)(b) 18(1)(h) 60(o.1) Principal Issues: Whether actuarial fees incurred in connection with the division of pension benefits on marriage or common-law partnership breakdown are deductible in computing income? ... Podor February 29, 2016 Dear XXXXXXXXXX: Re: Deductibility of Actuarial Fees We are responding to your correspondence dated October 20, 2015 concerning the deductibility of actuarial fees incurred in connection with the division of pension benefits on marriage breakdown. ... Expenses (such as legal or actuarial fees) incurred in connection with the division or settlement of a right to pension benefits arising out of, or on a breakdown of, a marriage or common-law partnership are considered to be on account of capital. ...

Principal Issues: Deductibility of sales commission expenses incurred by mutual fund limited partnerships in connection with the distribution of mutual funds. ... Thompson Attention: XXXXXXXXXX March 10, 1995 Dear Sirs: Re: Mutual Fund Limited Partnerships This is in reply to your facsimile transmission dated February 21, 1995 concerning the deductibility of sales commission expenses incurred by mutual fund limited partnerships in connection with the distribution of mutual funds. ... As noted therein, a limited partnership which incurs sales commission expenses in connection with the distribution of mutual funds before June 30, 1995 will be allowed to amortize these expenses in the following manner. ...

Principal Issues: An individual, in connection with his or her wedding consulting business, purchases a tuxedo. The tuxedo is worn to weddings in connection with the individual’s business. ... You have indicated that you operate a wedding consulting business and that you wear a tuxedo when you are present at a wedding in connection with your business. ...

To qualify for the OETC, a Canadian resident individual must: (a) be employed by a specified employer (generally, a resident of Canada), other than for the performance of services under a prescribed international development assistance program of the Government of Canada: (b) be employed in connection with a contract (or for the purpose of obtaining such a contract) under which the specified employer carried on business outside Canada with respect to the exploration for or exploitation of petroleum, natural gas, minerals or other similar resources, with respect to any construction, installation, agricultural or engineering project or with respect to an activity performed under contract with the United Nations; and (c) have performed all or substantially all the employment duties in connection with the contract outside Canada. ... During a period of absence from a work location outside Canada, an individual may take vacation time, consult with the specified employer in Canada or perform duties of employment in Canada and still remain eligible for the OETC provided that, throughout the period, substantially all of the individual's employment duties (90% or more) are performed outside Canada in connection with a qualifying activity of the employer. ... In general, the determination will be made by comparing the actual time an individual spent performing qualifying duties (duties performed in connection with a qualifying activity) to the total time the individual spent performing all employment duties during that period. ...

Reasons: The individual is a volunteer and is not remunerated for any services but is reimbursed for the cost of an internet connection. ... The particular individual was reimbursed for the cost of an Internet service connection that was used by him in connection with the volunteer services that he provided to the Institution. ... You have asked whether the reimbursement for the cost of the Internet service connection was required to be reported on Form T1204 by the payer. ...

To qualify for the OETC, an individual must: (a) be employed by a specified employer (generally, a resident of Canada), other than for the performance of services under a prescribed international development assistance program of the Government of Canada: (b) be employed in connection with a contract (or for the purpose of obtaining such a contract) under which the specified employer carried on business outside Canada with respect to the exploration for or exploitation of petroleum, natural gas, minerals or other similar resources, with respect to any construction, installation, agricultural or engineering project or with respect to an activity performed under contract with the United Nations ("qualifying activity"); and (c) have performed all or substantially all the employment duties (done in connection with a contract described in (b) above) outside Canada. ... During a period of absence from a work location outside Canada, an individual may take vacation time, consult with the specified employer in Canada or perform duties of employment in Canada and still remain eligible for the OETC, provided that throughout the qualifying period substantially all of the individual's employment duties (90% or more) are performed outside Canada in connection with a qualifying activity of the employer. ... In general, the determination will be made by comparing the actual time an individual spent performing qualifying duties (duties performed in connection with a qualifying activity) to the total time the individual spent performing all duties during that period. ...

14 March 2007 External T.I. 2007-0227011E5- Education credit- course related to employment Unedited CRA Tags 118.6 Principal Issues: Two questions are posed: (1) Is a course taken in connection with one's job eligible for the education tax credit? ... For years prior to 2004, the former definition of "qualifying educational program" in the Income Tax Act excluded any program taken by a student: (a) during a period for which the student received income from an office or employment, and (b) 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 is eligible for the education tax credit. ...

If the above exemption is not applicable, you are concerned with Revenue Canada's interpretation of the expression "in connection with" as used in such subparagraph. ... That subparagraph does not provide for an exemption from withholding tax where the payment is made in connection with the sale of property or the negotiation of a contract as does subparagraph 212(1)(d)(iii) of the Act. ... The expression "in connection with" would appear to have a broad connotation, however, as indicated in the case of Gene A. ...

Pursuant to Article 21, a Norwegian resident who carries on activities in Canada in connection with the exploration or exploitation of the seabed and subsoil and their natural resources is deemed to be carrying on a business in Canada through a permanent establishment or fixed base situated therein. We note that this provision only requires that the Norwegian resident carry on activities in connection with the exploration and exploitation of the natural resource of Canada, which in our view is a lower threshold than carrying on a business. However, those activities must be in connection with the exploration or exploitation of the seabed and subsoil and their natural resources. ...

One test is that the individual perform all or substantially all the duties of his employment outside Canada "... in connection with a contract under which the specified employer carried on business outside Canada with respect to... ... The expressions "in connection with" and "with respect to" are considered to have very broad meanings. ... Department's Position Non-operating support personnel, who otherwise meet the criteria set out in section 122.3 of the Act and who were employed by a specified employer in connection with a contract under which the specified employer carried on a business outside Canada in a qualified activity, will be eligible to claim the OETC. ...