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Technical Interpretation - External

23 January 2008 External T.I. 2007-0241391E5 - Withholding tax on payments made by a guarantor

Nevertheless, we offer the following general comments in connection with your request. ...
Technical Interpretation - External

15 July 2009 External T.I. 2008-0289731E5 - Forgiveness of Accrued Interest

Nevertheless, we offer the following comments in connection with your request. ...
Technical Interpretation - External

21 May 2014 External T.I. 2014-0528021E5 - Classification of Timber Limits

Where different parts of the class were used in connection with different timber limits or sections thereof, separate rates are computed for each part of the class as though each part of the class were the taxpayer's only property of that class. ...
Technical Interpretation - External

6 November 2014 External T.I. 2014-0537851E5 - research grant, fellowship, employment income

Scholarship Exemption Paragraph 56(3)(a) of the Act applies to fully exempt an amount that would otherwise be included in an individual's income under subparagraph 56(1)(n)(i) of the Act when the amount is received in connection with the individual's enrolment as a student in an educational program that is eligible for the education tax credit. ...
Technical Interpretation - External

16 March 2015 External T.I. 2014-0521791E5 - Estate Trustee Fees

Fees earned by a taxpayer for acting in the capacity of estate trustee in the course of business form part of the business income of the taxpayer, and expenses incurred in this connection are deductible in the usual way in computing such income, to the extent they are not recoverable from the funds of the estate. ...
Technical Interpretation - External

4 March 2014 External T.I. 2013-0513251E5 - Ecogifts

In the situation described, it would be necessary to review the terms and conditions of the agreement between the party transferring the compensation obligation and the consultant accepting the obligation, the conservation agreement between the landowner and the eligible recipient as well as any other relevant documents in connection with this arrangement. ...
Technical Interpretation - External

10 August 2012 External T.I. 2012-0436411E5 - Accumulated Profits

In connection with this use, the purpose test will be met if the borrowed money replaces capital (contributed capital or accumulated profits) that was being used for purposes that would have qualified for interest deductibility had the capital been borrowed money (eligible purposes). ...
Technical Interpretation - External

6 November 2012 External T.I. 2012-0443291E5 - Exemption of Indian's Employment Income

It also requires that the employer be an Indian band that has a reserve, or a tribal council representing one or more Indian bands that have reserves, or an Indian organization controlled by one or more such bands or tribal councils, if the organization is dedicated exclusively to the social, cultural, educational, or economic development of status Indians who for the most part live on a reserve, and that the duties of employment are in connection with the employer’s non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserve. ...
Technical Interpretation - External

17 July 2015 External T.I. 2014-0516501E5 - Educational assistance

The deduction applies only to assistance for tuition fees and not to other types of assistance a student may receive in connection with the student's training. ...
Technical Interpretation - External

19 June 2015 External T.I. 2013-0475751E5 - Withholding Tax on Royalty Payments

However, this general exception will not apply where the work in question is for the use or reproduction in Canada of either: a motion picture film, or a film, videotape or other means of reproduction for use in connection with television. ...

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