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Principal Issues: Whether the 6 consecutive month test in section 122.3 could be satisfied notwithstanding that the employee performed services in connection with two contracts and returned to Canada in the interim. ... Reasons: The application of subsection 122.3(1) to such case would primarily be limited by the requirement that during the relevant period the employee performed all or substantially all of his duties of employment outside Canada in connection with a qualifying contract. ... Our Comments 1) The fact that the employee performs his duties of employment in connection with more than one contract does not in and of itself disqualify an OETC claim under the provisions of subsection 122.3(1) of the Act. ...

In other words, in order for paragraph 255(b) of the Act to apply to include in Canada the seas and airspace above those submarine areas referred to in paragraph 255(a) of the Act, the activities of the enterprise have to be carried on in connection with the exploration for or exploitation of the minerals, etc. in those submarine areas. Since the ship in question does not engage in any activities in connection with such exploration or exploitation, paragraph 255(b) of the Act does not apply to include the seas or airspace above those submarine areas for the purpose of the Act. ... Furthermore, it is doubtful that all or substantially all of the duties of the crew members’ employment are exercised outside Canada and are in connection with a contract under which their employer carried on business outside Canada with respect to qualified activities. ...

18 April 2013 External T.I. 2013-0484631E5- Employee Bursary & Education Tax Credit CRA Tags Regulation 200(2) 6(1)(a) 118.5 118.6 Principal Issues: Change in position taken in Document 2012-043551 Position: ETC is in fact available to an individual taking a course in connection with his or her employment, provided all other requirements for the ETC are met. ... The ETC is in fact available to an individual taking a course in connection with his or her employment, provided all other requirements for the ETC are met. ...

Dodd (613) 957-8953 Attention: XXXXXXXXXX January 14, 1997 Dear Sirs: Re: Section 19 of the Income Tax Act We are writing in connection with your letter dated October 22, 1996. ... At the same time, we would note in connection with your concern regarding subsection 19(8) of the Act that the application of this provision is a question of fact on which it may not be possible to predetermine all of the relevant facts. ...

In general, as we stated in our previous letter, amounts paid into a plan in connection with the assets of a plan are not considered advantages to the plan's annuitant.  Expanding on this, we can also state that expenses incurred by a trustee in the overall maintenance of a plan's assets will generally be considered to be in connection with the plan's assets. ...

New paragraph 85(1)(c.2) of the Act as enacted by Bill C-18 applies where a taxpayer carrying on a farming business, the income from which is computed in accordance with the cash method, transfers to the corporation property, which was inventory owned in connection with that farming business immediately before the transfer of the property to the corporation. ... Pursuant to new subparagraph 85(1)(c.2), a growing crop of plants acquired on a subsection 85(1) rollover by a corporation in connection with a cash method farming business would be purchased inventory of the corporation for purposes of paragraph 28(1)(c) of the Act. ...

Paragraph 122.3(1)(b) of the Act states that throughout the qualifying period all or substantially all of the duties of employment must be performed outside Canada and the work must be done in connection with a contract under which the employer carries on business outside Canada. ... The duties performed by an individual outside Canada during a qualifying period in connection with a qualifying activity of a specified employer (qualifying duties) are compared to all of the duties that the individual performed for that employer during the same period. ... When the aggregate of the employment duties performed outside Canada in connection with ineligible activities and those performed in Canada in connection with any activity represent more than 10% of all the employment duties, the individual will not meet the "all or substantially all" test. ...

For example, reasonable allowances for the use of a motor vehicle in connection with the duties of employment may be excluded by virtue subparagraph 6(1)(b)(v), (vi) or (vii.1) of the Act. ... However, the flat rate allowance is still deemed unreasonable by virtue of paragraph 6(1)(b)(x) of the Act and must be included in the employee's income, since it is not based solely on the number of kilometres for which the motor vehicle is used in connection with the duties of employment. ... You should also note that an employee who receives any allowance(s) for the use of a motor vehicle in connection with the duties of employment that was not included in computing employment income for the year because of paragraph 6(1)(b) of the Act is not eligible to deduct motor vehicle expenses under paragraph 8(1)(h.1). ...

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 subsequent receipt, where the primary purpose of the receipt was compensation for the loss of employment. Two questions set out by the Courts to determine whether a connection exists for purposes of a retiring allowance are as follows: 1- But for the loss of employment would the amount have been received? ... We note, however, that damages received in connection with a loss of employment fall within the definition of a retirement allowance. ...

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 subsequent receipt, where the primary purpose of the receipt was compensation for the loss of employment. ... Two questions set out by the Courts to determine whether a connection exists for purposes of a retiring allowance are as follows: 1- But for the loss of employment would the amount have been received? ... We note, however, that damages received in connection with a loss of employment fall within the definition of a retirement allowance. ...