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Technical Interpretation - External

27 July 1999 External T.I. 2000-0020595 - Translation of 9916225 options + RRSP

In our view, this provision does not contemplate the situation where an amount is included in the income of the employee/annuitant in connection with payment of a benefit in accordance with subsection 146(8) even if a benefit resulting from an office or employment pursuant to paragraph 7(1)(c) has already been included in his income. ...
Technical Interpretation - External

21 June 2000 External T.I. 2000-0027545 - Labour-sponsored Funds credit carry-over

Nevertheless, we offer the following general comments in connection with your request which we hope are of assistance to you. ...
Technical Interpretation - External

7 April 2000 External T.I. 2000-0028125 - TERM PREFERRED SHARE CONVERSION

Nevertheless, we offer the following general comments in connection with your request which we hope are of assistance to you. ...
Technical Interpretation - External

11 July 2000 External T.I. 2000-0033235 - IT 445 AND TRUST/BENEFICIARY

Nevertheless, we offer the following general comments in connection with your request which we hope are of assistance to you. ...
Technical Interpretation - External

6 July 2000 External T.I. 2000-0019655 - STANDBY CHARGE - TAKING AUTO HOME

Generally, the value of automobile benefits is an amount equal to a prescribed amount per kilometre for operating costs in connection with personal use, and a "reasonable standby charge". ...
Technical Interpretation - External

28 August 2000 External T.I. 2000-0016035 - REASONABLENESS OF EMPLOYEE BONUS

As you noted in your letter, Revenue Canada's answer to question 42(3) at the 1981 Canadian Tax Foundation Round Table Discussion stated, in part: In general, the Department will not challenge the reasonableness of salaries and bonuses paid to the principal shareholder-managers of a corporation when (a) the general practice of the corporation is to distribute the profits of the company to its shareholders-managers in the form of bonuses or additional salaries; or (b) the company has adopted a policy of declaring bonuses to the shareholders to remunerate them for the profits the company has earned that are, in fact, attributable to the special know-how, connections, or entrepreneurial skills of the shareholders. ...
Technical Interpretation - External

9 August 2000 External T.I. 2000-0029185 - ESTATE DESIGNATES CHARITY AS BENEFICIARY?

Nevertheless, we offer the following general comments in connection with your request which we hope are of assistance to you. ...
Technical Interpretation - External

13 September 2000 External T.I. 2000-0036825 - REPURCHASE OF DEBENTURES ON OPEN MARKET

Nevertheless, we offer the following general comments in connection with your request which we hope are of assistance to you. ...
Technical Interpretation - External

23 November 2000 External T.I. 2000-0054915 - Partnership Funding Sales Commissions

For example, in connection with section 143.2 of the Act, in its December 14, 1995 press release, the Department of Finance referred to "the Government's commitment, announced on December 1, 1994, to improve the fairness of the tax system by preventing abuses through aggressive tax shelter promotions". ...
Technical Interpretation - External

10 January 2001 External T.I. 2000-0044955 - MEAL ALLOW. PAID BY EMPLOYERS

Subparagraph 6(1)(b)(vii) applies where an allowance for travel expenses, other than a motor vehicle allowance, is received by an employee (other than one employed in connection with the selling of property or negotiating of contracts for the employer), and the allowance is a reasonable amount, the allowance is received for travelling away from the municipality and the metropolitan area (if there is one) where the employer's establishment, at which the employee ordinarily worked or to which the employee ordinarily reported, is located, and the travelling is done in the performance of the duties of the office or employment. ...

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