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Technical Interpretation - Internal
3 March 1995 Internal T.I. 9504487 - INDIAN EMPLOYEE OF NON-PROFIT COMPANY
Whether or not the employer is an organization described in Guideline 4, an employee will be tax exempt under Guideline 4 only if the duties of the employment are in connection with the employer's non-commercial activities. ...
Technical Interpretation - Internal
7 June 2001 Internal T.I. 2001-0069430 - Specified Employer
We should note, however, that where the employer is the government, the issue that generally arises is whether the duties of the individual's employment outside Canada were "in connection with a contract with which the specified employer carried on business outside Canada". ...
Technical Interpretation - Internal
12 September 2001 Internal T.I. 2001-0090037 - XXXXXXXXXX
Paragraph 56(1)(n) of the Act provides that all amounts received by a taxpayer as or on account of a scholarship, fellowship or bursary, or a prize for achievement in a field of endeavour ordinarily carried on by the taxpayer are included in income to the extent that the total of these amounts received in the year exceeds $500 for years prior to 2000 and for the 2000 and subsequent taxation years provides for an additional $2,500 exemption in connection with the taxpayer's enrolment in a program in respect of which the taxpayer may claim the education tax credit. ...
Technical Interpretation - Internal
5 May 2000 Internal T.I. 2000-0017147 - Website Development Costs
Costs may also include registration fees and payment to an Internet provider who will furnish an Internet address and connections to various search engines. ...
Technical Interpretation - Internal
1 March 2001 Internal T.I. 2001-0070727 - SOCIAL ASSISTANCE;ADOPTION
There is no indication that you have an employment relationship with the Missouri DSS in connection with the care of your children. ...
Technical Interpretation - Internal
11 September 1989 Internal T.I. 58439 F - Intercorporate Dividends and Part IV Tax
Leung (613) 957-2116 September 11, 1989 Dear Sirs: Re: Subsection 55(2) and Part IV of the Income Tax Act (the "Act") This is in reply to your letter of July 26, 1989 wherein you requested our opinion with respect to the application of subsection 55(2) and Part IV of the Act in connection with the following hypothetical fact situation. 1. ...
Technical Interpretation - Internal
6 July 1989 Internal T.I. 58087 F - Overseas Employment Tax Credit
Specifically, you requested the Department's views as to whether the field of architecture is qualified activity and whether an employer would be considered to be carrying on a business in a foreign country to which an employee was sent to perform duties in connection with a contract under which the employer provided architectural services to a construction company resident in that country. ...
Technical Interpretation - Internal
29 March 1990 Internal T.I. 59429 F - Tax Shelter Reporting
As described in paragraph 3 of Information Circular IC 89-4, paragraph 237.1(1)(b) of the Act defines a tax shelter as any property of which it is expected, based on statements or representations made or proposed to be make in connection with the property, that the aggregate of losses or other amounts, calculated in any of the relevant years, which a purchaser will be entitled to deduct in taxation years ending within four years of the date of acquisition of the property will exceed the cost of the interest in the property (less prescribed benefits) to the purchaser. ...
Technical Interpretation - Internal
30 June 1989 Internal T.I. 32449 F - Whether or not Discount on Issuance of a Zero-coupon Bond Would be Interest
Donnelly (613) 957-3500 June 30, 1989 Dear Sirs: Re: Advance Income Tax Ruling Request 24(1) Proposed Note Issue We are writing in connection with your letters of April 25, 1898 and June 9, 1989 and your telephone discussions with Kevin Donnelly on May 11, 1989 and June 19, 1989. ...
Technical Interpretation - Internal
5 April 1990 Internal T.I. 59179 F - Clarification of First Condition on Form T626 for OETC
(ii) The contract in connection with which an employee performs duties in a foreign country must be one under which the specified employer carried on business in the foreign country. ...