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Technical Interpretation - Internal

11 April 2006 Internal T.I. 2006-0169571I7 F - Provision pour recours collectif

They import such meanings as "in relation to", "with reference to" or "in connection with". The phrase "in respect of" is probably the widest of any expression of any expression intended to convey some connection between two related subject matters. ...
Technical Interpretation - Internal

29 December 1994 Internal T.I. 9432817 - EMPLOYMENT INCOME - STATUS INDIAN

In order for an employee of an organization which is controlled by a band or tribal council to be exempt under Guideline 4, the organization must be resident on a reserve and must be dedicated exclusively to the social, cultural, educational, or economic development of Indians who for the most part live on reserves; and the duties of the employment must be in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserves. ... In order to fit within Guideline 4, inter alia, the duties of the employment must be in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserves. ...
Technical Interpretation - Internal

26 May 1995 Internal T.I. 9513756 F - CSST

They import such meanings as "in relation to", "with reference to" "in connection with". The phrase "in respect of" is probably the widest of any expression intended to convey some connection between two related subject matters. 4 En considérant l'opinion de la Cour Suprême et les articles de la Loi sur les accidents de travail mentionnés ci-avant, nous sommes d'opinion que les sommes que XXXXXXXXXX a reçues en vertu de l'article 178 de la Loi sur les accidents de travail doivent être ajoutées dans le calcul de son revenu en vertu de l'alinéa 56(1)v) de la Loi. ...
Technical Interpretation - Internal

14 June 2002 Internal T.I. 2001-0096897 - SUPPLEMENTARY EMPLOYEE RETIREMENT PLAN

The taxpayer's representatives argue that the SERP is not an RCA as no contributions have been made in connection with benefits that are to be received by employees upon a substantial change in their services, retirement or loss of office. ... Reference may also be made to document 90060 dated November 1, 1990 in which we confirmed that a personal guarantee by a major shareholder of a corporation in connection with retirement benefits provided by the corporation did not constitute an RCA as it was not a contribution to another person. ...
Technical Interpretation - Internal

24 June 2002 Internal T.I. 2002-0140707 - RPP FUNDING

Nevertheless, the technical notes to paragraph 8502(d) provides that in addition to the distributions that are listed, a plan may provide for the payment of all reasonable administrative, investment and similar expenses incurred in connection with the plan. ... Nevertheless, the July 31, 1991 Technical Notes to paragraph 8502(d) of the Regulations provides that in addition to the distributions that are listed, "a plan may provide for the payment of all reasonable administrative, investment and similar expenses incurred in connection with the plan". ...
Technical Interpretation - Internal

15 February 1999 Internal T.I. 9831987 - DIVISION OF ASSETS - DIVORCE

In connection with your request, you have provided us with a copy of the decision (the “Decision”) rendered by the Supreme Court of Newfoundland (the “Court”). ... In connection with the award of $XXXXXXXXXX, you have advised that XXXXXXXXXX paid the amount to Individual B and issued a T4A slip on the basis that the amount represented self-employment income to Individual B. ...
Technical Interpretation - Internal

19 November 2018 Internal T.I. 2018-0777321I7 - Tax treatment of a proposed XXXXXXXXXX program

Subsection 80.4(1) of the Act deems an interest benefit to arise where a taxpayer has received a low interest or interest-free loan in connection with a previous, current or intended office or employment. ... Moreover, the interest-free loans, under the proposed program, are not in connection with a previous, current or intended office or employment. ...
Technical Interpretation - Internal

16 May 1991 Internal T.I. 9012347 F - Determination of a Permanent Establishment

Stavanger Municipality, concerns a Swedish taxpayer operating a consulting company that was hired in connection with the hook-up of a drilling platform on the Norwegian continental shelf.  ... A legal opinion dated December 3, 1990 written by Francois Vincent of the Department of Justice deals with a similar situation involving 24(1) That opinion, a copy of which was sent to your Division, supports the views we expressed above. 24(1) In connection with this point, we note that Article VII of the 1980 Convention attributes business profits earned in Canada by a U.S. resident to a P.E. in Canada but, as stated in paragraph 7 thereof, only to the extent they are derived from the assets or activities of that P.E. ...
Technical Interpretation - Internal

9 December 1991 Internal T.I. 9126387 F - Requirements - Health and Welfare Trusts

Assuming that such a reserve would be established in connection with a self insured benefit plan, the amount of an employer's contribution to a health and welfare trust in respect of such a plan must be based on sound actuarial principles (The establishment of an arbitrary reserve that is contingent is not acceptable.). ... In connection with this comment, we also note that a shareholder or officer would not be considered an employee representative.  ...
Technical Interpretation - Internal

19 December 2022 Internal T.I. 2022-0932231I7 - Employ incom tax exemption under the Indian Act

The existence or creation of another viable transportation option in the remote area may result in a particular Off-reserve airport not being considered an integral source of transportation to the residents of the surrounding First Nations communities and would weaken the connection to a reserve. In addition, where the majority of passengers using the Off-reserve airport are no longer members of the First Nations, the connection would also be weakened. ...

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