Search - connection

In addition, either included in the written evidence authorizing the applicant to act for the taxpayer or in the advance ruling request should be a statement whether any of the issues involved in the ruling request are, to the best of the taxpayer's knowledge, being considered by a District Office and/or Taxation Centre in connection with a tax return already filed, or if any of the issues are under objection.  ...

Paragraph 6 of Article XI of the US Treaty states that "Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a State other than that of which he is a resident a permanent establishment or a fixed base in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment or fixed base, then such interest shall be deemed to arise in the State in which the permanent establishment or fixed base is situated and not in the State of which the payer is resident".  ...

It is also your understanding that neither the current position of the Minister as set out in IT-473 nor the proposed legislation require the approval of the Minister in connection with a change in the determination of "cost" where the lower of cost and market is used by the taxpayer for purposes of valuing inventory, provided the basis of determination of cost is in accordance with generally accepted accounting principles. ...

Generally, the use of land in excess of one-half hectare in connection with a particular recreation or lifestyle (such as for keeping pets or country living) does not mean that the excess land is necessary for the use and enjoyment of the housing unit as a residence. ...

The word "conjunction" is defined in The Oxford English Dictionary to mean "joining together, marriage union, connextion of ideas,...the action of conjoining; the fact or condition of being conjoined; union, connection, combination... ...

Your inquiry concerns the Part XIII withholding tax requirements on deemed shareholder benefits which arise in connection with interest-free loans made by a Canadian resident corporation ("Canco") to its non-resident corporate shareholder ("Holdco").  ...

., more than 50 percent) in connection with, or in the course of, the office or employment. ...

The following relevant factors demonstrate that the monthly payments have a significant connection to a reserve: The Elder payments are funded and administered by the First Nation, which is resident on a reserve. ...

Subsection 7(1.31) applies if the following conditions are met: the particular security is acquired under an agreement described in subsection 7(1); an identical security is disposed of within 30 days after the acquisition of the particular security; no other identical securities are acquired or disposed of by the employee after the acquisition of the particular security and before the disposition; the employee designates in the employee’s return of income filed for the year in which the disposition occurs that the particular security is the security subject to the disposition; and the employee has not designated the particular security in connection with the disposition of any other security. ...

For the purposes of determining the application of paragraph 104(2)(a), the remuneration must be an amount described in subparagraph 115(2)(e)(i) of the Act, which provides that the remuneration is in respect of duties of employment paid to a non-resident person by a resident of Canada, except to the extent that the amount is attributable to duties of employment performed by the non-resident outside Canada and is: (a) subject to an income or profits tax by a government of a country other than Canada; or (b) is paid in connection with the selling of property, the negotiating of contracts or the rendering of services, in the ordinary course of business carried on by the employer, a foreign affiliate of the employer or a person with whom the employer does not deal at arm’s length. ...