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To the extent that the taxpayer would be subject to tax in the United Kingdom on income earned or capital gains realized on investments held in the UK PPS or on amounts withdrawn from the UK PPS, a foreign tax credit may be available on the taxpayer's Canadian tax return in connection with any taxes paid to the government of the United Kingdom. ...

An individual’s use of the land in excess of one-half hectare in connection with a particular lifestyle does not, in itself, mean that the excess land is necessary for the use and enjoyment of the housing unit as a residence as noted in the court case Rode v. ...

A connection cannot be made between the expenditure and the exploration and development work performed. 2. ...

In the Explanatory Notes issued by the Department of Finance in connection with the introduction of subsection 87(8.2), it was stated: “New subsection 87(8.2) of the Act clarifies the circumstances in which certain foreign "absorptive mergers" will qualify as "foreign mergers" under subsection 87(8.1) of the Act. ...

For Officers, subsection 81(3) of the ITA provides a further exception to the general rule that allowances paid in connection with an office or employment are taxable. ...

Whether damages received in connection with a settlement agreement are taxable. 2. ...

The broad wording of this provision means that a taxable benefit may exist where there is any connection between the particular payment or benefit and the particular office or employment. ...

In your submission, you question the position that our Directorate took in response to a question at the CRA Roundtable session at the CLHIA Conference in May 2013 in connection with the applicability of the advantage tax rules in Part XI.3 of the Income Tax Act (the “Act”) where a retirement compensation arrangement (RCA) trust owns a life insurance policy (2013-0481421C6). ...

The submission questions the position that our Directorate took in response to a question at the CRA Roundtable session at the CLHIA Conference in May 2013 in connection with the applicability of the advantage tax rules in Part XI.3 of the Income Tax Act (the “Act”) where a retirement compensation arrangement (RCA) trust owns a life insurance policy (2013-0481421C6). ...

Paragraph XII(4) states as follows: "The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including motion pictures and works on film, videotape or other means of reproduction for use in connection with television), any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, tangible personal property or for information concerning industrial, commercial or scientific experience, and, notwithstanding the provisions of Article XIII (Gains), includes gains from the alienation of any intangible property or rights described in this paragraph to the extent that such gains are contingent on the productivity, use or subsequent disposition of such property or rights. ...