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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. ...

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