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Centre Internship Award and Professional Development Award Services in connection with these awards are performed in Canada and the income therefrom is considered income from employment performed in Canada. ... Pearson Fellowship Award Income from the performance of services in connection with this award is considered employment income. ... Journalism Award Services in connection with this award are performed outside of Canada. ...

Income Tax Convention (the “Convention”) with regard to certain “enhanced policy benefits” that may be received, in connection with a demutualization, in respect of certain life insurance policies held by U.S. residents. ... Under paragraph 139.1(4)(a) of the Draft Legislation, for the purposes of that section, where benefits under an insurance policy are enhanced in connection with a demutualization, the value of the enhancement is deemed to be a benefit received by the policyholder and not by any other person. ... Pursuant to subsection 139.1(8) of the Draft Legislation where, in connection with a demutualization of an insurance corporation, a stakeholder receives a “specified insurance benefit” the stakeholder is deemed to have paid and the corporation is deemed to have received, at the time of the demutualization, a premium in respect of the policy to which the benefit relates equal to the value of the benefit. ...

Friedlander August 25, 2014 Dear XXXXXXXXXX: Re: Investment Counselling Fees for RDSP Property We are responding to your email of April 4, 2014, concerning certain investment counselling fees paid in connection with a registered disability savings plan (an "RDSP"). You are asking about a deduction under paragraph 20(1)(bb) of the Income Tax Act (the "Act") for investment counselling fees that are paid in connection with investments in a RDSP. ...

Position: No Reasons: There must be a connection between the actual travel cost and the amount received by the employer to defray those costs. 972880 XXXXXXXXXX J.E. ... " In our opinion, there must be a connection between the actual travelling expenses incurred by the taxpayer or a member of the taxpayer's household and the amounts paid by the taxpayer's employer to defray those costs. ...

In this respect, these terms suggest a connection to horses. Accordingly, it is our view that, in this context, a “stable” means “a building set apart and adapted for keeping horses.” Therefore, the phrase “stable equipment” refers only to equipment which is used in connection with a stable for horses. ...

Principal Issues: We have been asked to be of assistance with respect to the commutation of an annuity contract issued in connection with a structured settlement arrangement and the payment of the related lump sum to the claimant. ... As a result of your financial circumstances, you have asked us whether the remaining payments in respect of the two annuity contracts issued in connection with the structured settlement, could be commuted by the owner (insurer) and the two related lump sum amounts paid to you. ...

Principal Issues: We have been asked to be of assistance with respect to the commutation of an annuity contract issued in connection with a structured settlement arrangement and the payment of the related lump sum to the claimant. ... As a result of your financial circumstances, you have asked us whether a portion of the payments in respect of the annuity contract in connection with the structured settlement, could be commuted by the owner (insurer) and the related lump sum amounts paid to you. ...

It is our understanding that 24(1) In order for an individual to be eligible to claim the OETC, in addition to meeting other conditions set out in subsection 122.3(1) of the Income Tax Act (the "Act"), the individual is required to 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 in such country or countries with respect to the qualified activities set out in paragraph 4(c) of Interpretation Bulletin IT-497R2. Based on the limited facts provided in your letter of October 25 and November 29, 1991. 24(1) In order for you to qualify for the OETC it would be necessary for  24(l) Co to demonstrate that they are carrying on business in Mexico in connection with a contract with respect to one or more of the qualified activities.  ...

It is our view that where the Canadian cable TV companies pick up distant signals which are transmitted from films or video tape, any payments made in respect of the retransmissions of such signals will fall within the wording of paragraph 212(5)(b) of the Act as payments for the use of "a film, video tape or other means reproduction for use in connection with television". In the case where live broadcasting of a sporting or other events are retransmitted, we are of the view that such payments will fall within the words "or other means of reproduction for use in connection with television" used in paragraph 212(5)(b) of the Act. ...

The individual cannot have been employed or engaged by the employer in the same year, otherwise than as a volunteer, in connection with the performance of any of the duties described, or similar duties. Based on the information provided, it is our view that the individual does not qualify for the exemption under subsection 81(4) of the Act because the individual performs firefighter duties in connection with his employment with the municipality. ...