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Technical Interpretation - External

18 April 1996 External T.I. 9602285 - FOREIGN PENSION, PENSION ADJUSTMENT

In general, a prescribed contribution is a contribution made after 1991 to a foreign plan where the employer elects to report pension adjustments in connection with the participation of the employees in the foreign plan and certain other conditions are satisfied. ...
Technical Interpretation - External

22 April 1996 External T.I. 9533185 F - ALLOCATION DE FIN DE CARRIERE

Younge-Eglinton Building Ltd, 74 DTC 6181, l'expression «in the course of» est défini comme signifiant «in connection with», or «incidental to» or «arising from». ...
Technical Interpretation - External

16 May 1996 External T.I. 9608565 - LEGAL FEES - SPOUSAL SUPPORT ENFORCEMENT

Principal Issues: whether legal fees incurred in connection with the enforcement of court ordered payments are deductible under the circumstances described. ...
Technical Interpretation - External

15 July 1996 External T.I. 9617645 - DEREGISTERED RPP TRANSFER TO FOREIGN PLAN

A "qualifying entity" is: "a non-resident trust, corporation or other entity that (a)is resident in a country under the laws of which an income tax is imposed, (b)is exempt under the laws referred to in paragraph (a) from the payment of income taxes to the government of the country of which it is a resident, and (c)was established or incorporated principally in connection with, or the principal purpose of which is to administer or provide benefits under, one or more superannuation, pension or retirement funds or plans or any funds or plans established to provide employee benefits. ...
Technical Interpretation - External

27 May 1996 External T.I. 9607705 - EXEMPT ALLOWANCES

In connection with the first issue, it must be determined whether elected board members of the above noted board are described under paragraph 81(3)(b) of the Income Tax Act (the Act). ...
Technical Interpretation - External

8 August 1996 External T.I. 9616635 - NO ATTRIBUTION ON THE RETURN OF PROPERTY TO A SPOUSE

Finally, on the assumption that the promissory note issued in connection with the return of the shares was interest-bearing and that the interest was in fact paid within 30 days of the end of the calendar year, you ask whether such interest would attribute to spouse A who was required to pay the interest, thereby offsetting the deduction you assume would otherwise be available to him in respect of the interest paid. ...
Technical Interpretation - External

16 August 1996 External T.I. 9618015 - WRONGFUL DISMISSAL SETTLEMENT

As mentioned, generally, payments made by an employer to an employee in connection with a loss or termination of employment, whether or not received as damages or pursuant to an order of a competent tribunal, would be characterized as a retiring allowance. ...
Technical Interpretation - External

29 January 1997 External T.I. 9626495 - POTENTIAL SWISS BANK ACCOUNT

The appropriate tax treatment in connection with a Swiss bank account which your late father or the company that his business partners in Scotland incorporated ("FCo") might have had, depends very much on the facts and circumstances of the situation. ...
Technical Interpretation - External

6 April 1993 External T.I. 9304245 F - Retirement Compensation Arrangement - Letter of Credit

Where an employer agrees to pay an annual pension to an employee under a non-registered pension plan upon termination of his employment and the employer makes a single contribution of $100 to a trust in connection with the arrangement, it is your view that all pension payments under the arrangement are payments out of an RCA notwithstanding that a contribution of only $100 was made. ...
Technical Interpretation - External

30 June 1993 External T.I. 9307505 F - Substitute Teachers and Travelling

In connection with the above circumstances, you have indicated that the school board does not pay any transportation costs to the occasional teacher and public transportation is generally unavailable. ...

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