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We apologize for the delay in responding to you, which arose because we considered it necessary to undertake consultations with the Department of Finance in connection with subparagraph 7(b) of Article 13 of the Convention. ...

Concerning a fixed monthly or annual car allowance, it is our view that such an allowance would be taxable to the recipients by virtue of subparagraph 6(1)(b)(x) of the Act as the allowance would not appear to be based solely on the number of kilometres for which the motor vehicle is used in connection with or in the course of their office or employment. ...

Duff   (613) 957-8953 Attention:  19(1) April 7, 1992 Dear Madam: Re:  Qualified Investments in a Registered Retirement Savings Plan This is to inform you of the Department's position concerning the situation when a trust governed by a registered retirement savings plan ("RRSP") acquires foreign currency in connection with transactions dealing with securities that are denominated in the foreign currency. ...

Duff   (613) 957-8953 Attention:  19(1) April 7, 1992 Dear Madam: Re:  Qualified Investments in a Registered Retirement Savings Plan This is to inform you of the Department's position concerning the situation when a trust governed by a registered retirement savings plan ("RRSP") acquires foreign currency in connection with transactions dealing with securities that are denominated in the foreign currency. ...

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". ...

19 February 2014 External T.I. 2013-0484761E5- Taxable Benefits – Employer-Provided Vehicles CRA Tags 6(1)(a) 6(1)(k) 6(1)(e) Principal Issues: Whether a taxable benefit would arise in connection with an employee's use of an employer-provided vehicle? ... Factors that may indicate that a pick-up location is a RPE for employees could include the following: the employer requires the employee to pick up the motor vehicle on a regular basis and at a specific time; the employee is paid by the employer from the time that he or she picks up the motor vehicle, until the motor vehicle is returned at the end of the work day; evidence that picking up the motor vehicle is a required duty of employment; evidence that the employee is required to perform employment-related duties in the motor vehicle or in connection with the motor vehicle prior to departing the pick-up location; the employee is entitled to receive workers' compensation benefits in respect of injuries he or she may sustain in the employer-provided motor vehicle while travelling from the pick-up location to a point of call or RPE. ...

To establish a substantial connection between the income and the reserve, the courts have indicated that one must identify and evaluate all the relevant components of the business, including the quantity, quality, and nature of the services provided and to whom the services are being rendered. ... Based on the information you submitted, the following factors demonstrate only a weak connection to the reserve: The business activities are carried out at XXXXXXXXXX off the reserve. ...

However, where an individual receives a "voluntary payment" or other valuable transfer or benefit from the individual's employer, or from some other person in connection with that employment, the amount of the payment or the value of the transfer or benefit must generally be included in the individual's income pursuant to subsection 5(1) or paragraph 6(1)(a) of the Act. Similarly, "voluntary payments" or other transfers or benefits received by a taxpayer in respect of, or in connection with, a business carried on by the taxpayer, must be included in the taxpayer's income from that business. ...

In very general terms, a “periodic pension payment” does not include a payment out of a RRIF where the total of all payments under the RRIF at or before the time of the payment and in the year, exceeds the greater of: (i) twice the amount that would be the “minimum amount” under the RRIF for the year, and (ii) 10% of the fair market value (“FMV”) of the property held in connection with the RRIF at the beginning of the year. ... Basically, the minimum amount is nil in the first year of the fund and, thereafter, the FMV of the property held in connection with the RRIF at the beginning of the year multiplied by a prescribed factor. ...

" The broad wording of this provision means that a taxable benefit may exist where there is any connection between a benefit and the particular office or employment. ... Parliament, has added the phrases "in the course of" and "by virtue of", to the phrase "in respect of" in order to emphasize that only the smallest connection to employment is required to trigger the operation of the section. ...