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Technical Interpretation - External
28 February 2001 External T.I. 2000-0061815 - free tuition
Under legislative proposals dated December 21, 2000, an additional $2,500 per year after 1999 is exempt from taxation in connection with programs for which the student is entitled to the education tax credit. ...
Technical Interpretation - External
10 April 2001 External T.I. 2001-0070365 - CCA CLASS FOR BLD. ON LEASE
In your letter, you requested our comments on the income tax treatment by a franchisee of building costs in connection with a franchise agreement with XXXXXXXXXX (the "franchiser"). ...
Technical Interpretation - External
26 March 2001 External T.I. 2001-0073495 - MANUFACTURING & PROCESSING
Qualified activities are listed in section 5202 "qualified activities" of the Income Tax Regulations and include any of the listed activities therein when they are performed in Canada in connection with the manufacturing and processing. ...
Technical Interpretation - External
19 April 2001 External T.I. 2001-0076675 - LCT INSTALMENT RECEIPTS/SPLITSHARES
Instalment receipts It is our understanding that, in connection with an arrangement to sell shares to the secondary market on an instalment basis, the shares are sold at a predetermined price with a portion of the sale price payable at the time of the sale and the balance to be paid at some future date in one or more instalments. ...
Technical Interpretation - External
5 June 2001 External T.I. 2001-0085555 - Paragraph 3(d) of Article XI
Paragraph 3(d) of Article XI of the Convention, as it read prior to the Third Protocol, was worded as follows: "the interest is beneficially owned by a seller who is a resident of the other Contracting State and is paid by a purchaser in connection with the sale on credit of any equipment, merchandise or services, except where the sale is made between persons dealing with each other not at arm's length;" (underlining for emphasis) Paragraph 3(d) of Article XI of the Convention was amended by the Third Protocol and currently reads as follows: "the interest is beneficially owned by a resident of the other Contracting State and is paid with respect to indebtedness arising as a consequence of the sale on credit by a resident of that other State of any equipment, merchandise or services except where the sale or indebtedness was between related persons;" (underlining for emphasis) The Technical Explanation to the Third Protocol, as it pertains to paragraph 3(d) of Article XI of the Convention, reads, in part, as follows: "...... ...
Technical Interpretation - External
24 May 2001 External T.I. 2001-0069045 - SHORT SALE AND IDENTICAL PROPERTIES
Nevertheless, we offer the following general comments in connection with your request which we hope are of assistance to you. ...
Technical Interpretation - External
28 June 2001 External T.I. 2001-0073205 - SUBSTANTIAL ISSUER BID
Nevertheless, we offer the following general comments in connection with your request which we hope are of assistance to you. ...
Technical Interpretation - External
8 November 2001 External T.I. 2001-0096075 - SR&ED - SOCIAL SCIENCES
Some of the items listed in this section include: prescribing the evidence required to establish facts relevant to assessments under this Act; requiring any class of persons to make information returns respecting any class of information required in connection with assessments under this Act; prescribing anything that, by this Act, is to be prescribed or is to be determined or regulated by regulation; and defining the classes of persons who may be regarded as dependent for the purposes of this Act. ...
Technical Interpretation - External
7 November 2001 External T.I. 2001-0103805 F - SENS D'ACTIFS
Bank of Toronto (1924), 56 O.L.R. 318, on indique ce qui suit: "'Assets' is a word that has different meanings in different connections..." ...
Technical Interpretation - External
29 November 2001 External T.I. 2001-0102455 - MEDICAL EXPENSES
In connection with motor vehicles and accommodations, the types of expenses that a person is permitted to deduct are limited, and they are described in IT-519R2. ...