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Technical Interpretation - External
12 November 1998 External T.I. 9823775 - AUTOMOBILE TAXABLE BENEFITS TO EMPLOYEES
This value is an amount equal to a prescribed amount per kilometre for operating costs in connection with personal use and a “reasonable standby charge” (plus the equivalent to the Goods and Services Tax (GST) on the standby charge). ...
Technical Interpretation - External
21 December 1998 External T.I. 9821615 - TRAVEL ALLOWANCES
Assuming that none of the eligible employees are employed in connection with the selling of property or negotiating of contracts for the employer, the tax treatment of an allowance paid for the use of a motor vehicle in the above circumstances depends on whether the conditions in subparagraph 6(1)(b)(vii.1) of the Act are satisfied. ...
Technical Interpretation - External
10 February 1999 External T.I. 9826855 - PRIME METAL STAGE OR ITS EQUIVALENT
To the extent that a taxpayer acquires any real property in Canada the principal value of which depends upon its mineral resource content (but not including any depreciable property used or to be used in connection with the extraction or removal of minerals therefrom), i.e., a “Canadian resource property” within the meaning of subsection 66(15) of the Act, the cost thereof is a “Canadian development expense” within the meaning thereof in subsection 66.2(5) of the Act. ...
Technical Interpretation - External
16 February 1999 External T.I. 9901435 - STATUS OF SUCCESSIVE TRUSTS
That interpretation is superceded by a recent legal opinion we obtained in connection with another file. ...
Technical Interpretation - External
3 March 1999 External T.I. 9827105 - RRIF DETERMINATION OF MIN. AMOUNT
In basic terms, the minimum amount is now the total of: a "prescribed fraction" for the year (as discussed in the enclosed bulletin) multiplied by the total fair market value of the property held in connection with the fund at the beginning of the year (other than certain annuity contracts), and the total (or an estimate thereof) of all periodic amounts received by a trust governed by the fund, under such an annuity held at the start of the year. ...
Technical Interpretation - External
21 April 1994 External T.I. 9329935 - MEANING OF "PENSION" - LUMP-SUM RRIF PAYMENT (7224-8)
In general, the definition states that 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 payment and in the calendar year exceeds the greater of: (a) twice the amount that would be the "minimum amount" under the fund for the year, and (b) 10% of the amount that would be the FMV of the property held in connection with the fund at the beginning of the year if all property transferred in the year and before that time to the carrier of the fund as consideration under the fund had been transferred immediately before the beginning of the year and if the definition "minimum amount" in paragraph 146.3(1)(b.1) of the Act were applicable with respect to all RRIFs. ...
Technical Interpretation - External
3 August 1994 External T.I. 9406075 - TUITION FEES
In connection with the methods referred to in 2(a) and (b) above, the information provided to us indicates that the PLA process involves an evaluation of an individual's past learning experience for the purpose of relating it to programs and/or courses offered by colleges which operate under the auspices of the Ontario Provincial Government. ...
Technical Interpretation - External
12 September 1994 External T.I. 9417285 - RELATED EMPLOYERS FOR RETIRING ALLOWANCE TRANSFER
Employer 2 then severs its connection with Employer 1 and is no longer a related person under the Act. ...
Technical Interpretation - External
9 November 1994 External T.I. 9421005 - EMPLOYMENT BENEFITS - STANDBY CHARGE
Company A would retain title to the vehicles and would be responsible for insuring them against loss or damage. 3.Company A is providing the automobiles as a condition of its sponsorship relationship to promote the visibility of the automobile with the activities of the charity. 4.An emblem identifying the charity is affixed to each automobile. 5.During normal working hours the automobiles are parked at the office of the charity and are available to the staff for use on charity business. 6.Before and after normal working hours the automobiles are used by key employees of the charity in connection with charity functions in their capacity as executives of the charity. 7.Executives of X normally drive the automobiles to and from work at the request of Company A so that the automobiles are seen at public functions. 8.The executives of X reimburse the charity on a per kilometre basis for the operating costs of the automobiles that relate to driving to and from work. 9.The executives of X own their own automobiles for other personal usage such as vacations and weekends. ...
Technical Interpretation - External
7 November 1994 External T.I. 9416935 - EMPLOYEE LOAN - INCOME INCLUSIONS
In connection with these comments, we also note that subsection 80.4(3)(b) of the Act provides that subsections 80.4(1) and (2) of the Act do not apply in respect of any loan or debt, or any part thereof, that was included in computing the income of a person under Part I of the Act. ...