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Technical Interpretation - External

1 March 2000 External T.I. 2000-0008135 - LEGAL FEES TO SETTLE AN ESTATE

Principal Issues: Whether legal fees incurred by a taxpayer in connection with a dispute with a sibling over farmland is tax deductible. ... As we understand the facts, the legal fees were incurred by a taxpayer in connection with a dispute with a sibling over farmland inherited from the parents. ...
Technical Interpretation - External

21 September 2000 External T.I. 2000-0040485 - NORTHERN RESIDENTS DEDUCTION

In general terms, the deduction offsets the income inclusion in respect of benefits provided by an employer to an employee or the employee's family with respect to trips made for the purpose of obtaining necessary medical services not available locally or with respect to travelling expenses in connection with not more than two other trips per year. ... " as required by paragraph 110.7(1)(a) of the Act, there must be a connection between the actual travel expenses incurred by a taxpayer or a member of a taxpayer's household and the amounts paid by the taxpayer's employer to defray those costs. ...
Technical Interpretation - External

15 November 2000 External T.I. 2000-0053395 - Allocation Taxable Income Between Provinces

The reference in subsection 402(5) of the Regulations to "that is not used in connection with the principal business operations of the corporation" refers only to "rentals or royalties from property" and not to the other items enumerated therein. ...
Technical Interpretation - External

18 May 1999 External T.I. 9908375 - EMPLOYER REIMBURSEMENT OF MORTGAGE INSURANCE

They import such meanings as "in relation to", "with reference to" or "in connection with". The phrase "in respect of" is probably the widest of any expression intended to convey some connection between two related subject matters. ...
Technical Interpretation - External

2 October 1989 External T.I. 58445 F - Employee Benefit Plans

All contributions made under the EBP after the establishment of the Statutory Arrangement and all property that can reasonably be considered to derive from those contributions are deemed to be property held in connection with the Statutory Arrangement and not in connection with the existing arrangement. ...
Technical Interpretation - External

4 December 1991 External T.I. 9027245 F - Royalty Payments by Canadian Cable TV Industry

Where the Canadian cable TV companies pick up distant signals which are transmitted from films or video tapes, any payments in respect of the retransmission of such signals will fall within paragraph 212(5)(b) of the Income Tax Act (the "Act") as payments for the use of a film, video tape or other means of reproduction for use in connection with television.  Where the signals of live broadcasts of sporting or other events are retransmitted by Canadian cable TV companies, such payments will also fall within the wording "or other means of reproduction for use in connection with television" and be subject to withholding tax in Canada when paid to non-residents of Canada. ...
Technical Interpretation - External

8 December 1992 External T.I. 9224555 F - Overseas Employment Tax Credit-Subcontracts (7970-7)

Section 122.3 of the Income Tax Act (the "Act") provides that where an individual is resident in Canada, and throughout any period of more than 6 consecutive months that commenced in the year or a previous year, was employed by a person who was a specified employer and performed all or substantially all of his duties of employment outside Canada in connection with a contract under which the specified employer carried on a business outside Canada with respect to qualified activities, he will be eligible to claim the OETC. ... The employees of the specified employer providing the data processing services would qualify to claim the OETC, provided they met the other conditions set out in subsection 122.3(1) of the Act, since their employment is in connection with a contract under which the specified employer carried on business outside Canada with respect to qualifying activities. ...
Technical Interpretation - External

9 July 2015 External T.I. 2013-0475421E5 - Section 94.2

Although section 94.2 is a relatively new provision of the Act, the question of how to compute FAPI in circumstances where complete and full information may not be accessible is not novel, as it has historically been relevant in connection with CFA status under former subparagraph 94(1)(d) (the predecessor of current section 94.2) and paragraph (b) of the definition of "controlled foreign affiliate" in subsection 95(1). ... Additional relief in connection with reporting requirements may be available on a case-by-case basis under subsection 220(2.1). ... Effectively, section 94.2, in conjunction with subsection 233.4(4), although with some expansion to the number of foreign entities subject to the provisions' requirements, maintains and accords with the policy announced by the Department of Finance in Budget 2010 of retaining and broadening the reporting requirements in connection with prior subsection 94(1). ...
Technical Interpretation - External

21 November 2005 External T.I. 2005-0143231E5 - Terminal Charge / ONT Tax Reduction

This amount could be further reduced if the employee is required by the employer to use the automobile in connection with or in the course of the office or employment and the distance travelled is primarily in connection with or in the course of that office or employment. ...
Technical Interpretation - External

4 September 1997 External T.I. 9638805 - INVESTMENT INCOME OF INDIANS - "CORPORATE DEBENTURES"

It appears that one of the main purposes for the existence of the corporation may be to serve as an artificial connection between the investment income of the Indian investors and a reserve, by acting as an intermediary between the Indians and their investments in securities listed on a stock exchange. It is our view that where an arrangement creates an artificial connection between income and a reserve, the arrangement will carry no weight as a connecting factor. ... In this regard, it should be noted that it is our view that where an arrangement creates an artificial connection between income and a reserve, the arrangement will carry no weight as a connecting factor. ...

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