Search - connection

" During a Municipality employee’s temporary assignment to a position of employment with Entity, Municipality agreed to continue making an automobile available to such employee (“Employee”) in connection with such temporary employment. ...

If…the taxpayer carries on two separate businesses…the income from the processing activity cannot be computed in accordance with the cash method of accounting provided for in section 28, and the processed meat cannot be considered as goods included in inventory in connection with a farming business. ...

27 July 2010 External T.I. 2010-0364841E5 F- Questions relatives à une séparation-- summary under Supporting Person Summary Under Tax Topics- Income Tax Act- Section 63- Subsection 63(3)- Supporting Person no supporting person where two spouses lived separate and apart under same roof In connection with finding that child care expenses incurred in the year, in the context of the correspondent living separate and apart from the correspondent’s spouse but their living under the same roof with their children, will be deductible by the parent who paid the child care expenses, provided that all the conditions for claiming the deduction are satisfied, CRA stated: [T]here does not appear to be a "supporting person" … in the situation you have presented to us, since even if you lived in the same household as your spouse, you likely did not "reside with" her at any time during the first 60 days of 2010 …. ...

28 June 2010 External T.I. 2010-0361561E5 F- Programme d'aide au développement international-- summary under Subparagraph 6(1)(b)(iii) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(iii) ordinary resident apparently eligible for the exclusion on overseas posting re international aid program After finding that the correspondent, who had received an allowance while stationed abroad in connection with a program that was funded as an international development assistance program (and who very well may have been a Canadian resident under ordinary jurisprudential principles), was not eligible for the overseas employment tax credit, CRA stated: However, subparagraph 6(1)(b)(iii) provides that representation or other special allowances received by a person in respect of a period of absence from Canada will not be included in computing the person's income if, among other things, paragraph 250(1)(d) applies to the person. … Consequently, to the extent that you resided in Canada at any time during the 3-month period before your start date … the allowance … that you receive while posted in that country is not required to be included in computing your income for the year in which you receive it. ...

Before commenting on this issue, CRA stated (in relation to the RCA strip charcterization): [T]he payment for life insurance coverage reduces the FMV of the subject property of the RCA trust each year as the amount paid for this protection is not invested in property held in connection with the RCA trust. ...

.- PART PRIVILÉGIÉE-- summary under Subsection 103(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 103- Subsection 103(1) common and preferred units can be used as a mechanism for profits to be allocated to each partner’s interest (a single property) In connection with a query on the implications of holding a preferred unit in a partnership, i.e., a unit that confers on its holder a preferred share of the partnership's profits or losses, CRA noted that division of a partnership interest into preferred and common units does not affect it being a single property, and stated: [T]here is nothing to prevent the creation of units with different rights with respect to the sharing of income, losses or other attributes of the partnership. ...

Indeed, the exception in subparagraph 6(1)(b)(vii) is intended to exclude allowances to compensate an employee for expenses incurred in connection with, and not as a result of, travel. ...

In rejecting a submission that this allowance should be construed as bifurcated into two allowances, one of which was reasonable as required by s. 6(1)(b)(x), CRA stated: [I]n determining the reasonableness of a travel allowance, the phrase "solely on the number of kilometres for which the vehicle is used in connection with or in the course of the office or employment” (emphasis added) in subparagraph 6(1)(b)(x) refers to the use of the vehicle for business purposes only. ...

21 March 2006 External T.I. 2005-0158451E5 F- Québec Mining Duties Act- Credit for Losses-- summary under Paragraph 12(1)(x.2) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x.2) credit under the Quebec Mining Duties Act based on exploration and development losses of operator was not includible under s. 12(1)(x.2) S. 32 of the Quebec Mining Duties Act (MDA) provided a credit to an operator equal generally to an amount not exceeding 12% of the lesser of (i) its annual loss (excluding the portion thereof attributable to ore processing activities) and (ii) the amount by which the expenses in respect of exploration, mineral deposit evaluation and mine development work, incurred by the operator for the fiscal period in connection with the mining operation, exceeds the amount of government assistance that the operator received or was entitled to receive relating to those expenses. ...

21 March 2006 External T.I. 2005-0158451E5 F- Québec Mining Duties Act- Credit for Losses-- summary under Paragraph 66(12.6)(a) Summary Under Tax Topics- Income Tax Act- Section 66- Subsection 66(12.6)- Paragraph 66(12.6)(a) credit under the Quebec Mining Duties Act based on exploration and development losses of operator was too remote from the exploration to reduce the renounced CEE S. 32 of the Quebec Mining Duties Act (MDA) provided a credit to an operator equal generally to an amount not exceeding 12% of the lesser of (i) its annual loss (excluding the portion thereof attributable to ore processing activities) and (ii) the amount by which the expenses in respect of exploration, mineral deposit evaluation and mine development work, incurred by the operator for the fiscal period in connection with the mining operation, exceeds the amount of government assistance that the operator received or was entitled to receive relating to those expenses. ...