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As indicated in paragraph 146.1(2)(j) of the Income Tax Act (the ("Act"), this connection is required only where the RESP permits more than one beneficiary at the same time. ...

13 August 1992 External T.I. 9207735 F- Resource Royalty Payments- Resource Profits Unedited CRA Tags 66(15) Canadian resource property, ITR 1206(9), ITR 1210(1)(a)(i)(a), ITR 1204(1)(b), ITR 1204(1)(b.1) 24(1) 920773   John Chan   (613) 957-8975 Attention:  19(1) Dear Sirs: Re:  Resource Royalty Payments This is in reply to your letter dated March 12, 1992 wherein you requested a technical interpretation in connection with the application of certain provisions of the Income Tax Act (the "Act") and the Income Tax Regulations (the "Regulations") to resource royalty payments in the context of a hypothetical fact situation.  ...

A net profit is earned by the parent company in connection with this since the funds advanced on an interest bearing basis are obtained by the parent partly by debt and partly by equity- as such, the interest income exceeds interest expense. ...

Savage, 83 DTC 5409, as a phrase with the widest possible scope intended to convey some connection between two related subject matters. ...

Where the Canada Business Corporations Act ("CBCA") is applicable, subparagraph 184(1)(b)(iii) thereof provides that on a vertical short-form amalgamation "no securities shall be issued by the amalgamated corporation in connection with the amalgamation. ...

Second, the amount must be "received in connection with the taxpayer's enrolment in an educational program in respect of which an amount may be deducted under subsection 118.6(2)"- that is, the individual must qualify for an education tax credit that is connected to an educational program that is connected to the amount. ... However, in our view, in many or most cases, the connection between the compensation received by a PDF (which has been referred to many times by universities, academics and post-doctoral fellows alike as "salary"), and an educational program, will be so slight as to be insufficient to warrant the application of the full scholarship exemption. ...

As long as the legal expenses in connection with the purchase of the subsequent home meet the requirements of subsection 62(1), they should be deductible since they are on account of moving expenses incurred in respect of an eligible relocation. ... Therefore, the central issue is whether the sales commissions and legal fees in connection with the sale of House A and the legal fees in respect of House B can be considered to be "as or on account of moving expenses incurred in respect of an eligible relocation". ...

It is not likely that the Folster decision applies; specifically, the location of the employer has no historical connection to a reserve. 2009-031803 XXXXXXXXXX L. ... In particular, there is nothing to suggest a clear historical connection between your employment situation and the local reserves. ...

.; Dco is a resident of the U.S. for the purposes of the Treaty and is a "qualifying person" as defined in Article XXIX A(2) of the Treaty; Canco and Dco are "related" as that term is defined in subsection 251(2) of the Act; Dco enters into an agreement with Canco under which Dco grants a royalty to Canco for the right to use certain property exclusively in connection with Canco's business operations in the U.S.; Canco makes royalty payments to Dco pursuant to the agreement; The royalty payments are payments described in paragraph 212(1)(d) of the Act and in Article XII(4) of the Treaty; The royalty payments are not payments described in subparagraphs (a) to (d) of Article XII(3) of the Treaty; Pursuant to Article XII(6)(a) of the Treaty, the royalty payments are deemed to arise in the U.S. and not in Canada; and Dco is required to include the royalties in its income for U.S. tax purposes. ... Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a State a permanent establishment in connection with which the obligation to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties shall be deemed to arise in the State in which the permanent establishment is situated and not in any other State of which the payer is a resident; In addition, paragraph 8 of Article XII restricts the right of a Contracting State to impose tax on royalties paid by a resident of the other Contracting State. ...

We note that where legal fees are paid in connection with various matters, they should be apportioned on a reasonable basis to determine what fees were paid in connection with collecting or establishing a right to a retiring allowance. ...