Search - connection

In addition, the taxpayer did not have an employment position at the time of the move although he expected to obtain an employment position in the near future (a few months) in connection with a manufacturing activity that was to be commenced. ... In connection with these comments, it is our view that if the "old residence" is considered to be the rental unit he occupied following the sale of his home until November of 1991, the costs would not be deductible. ... In connection with the comments in the preceding paragraph, we also wish to note that on page 2 of the individual's letter, it is indicated that he incurred costs of $XXXXXXXXXX (Legal fees and Deed transfer) in connection with the acquisition of the lot purchased in November of 1991 as well as costs (Legal fees) of $XXXXXXXXXX incurred in connection with the financing of the construction of the home. ...

British Columbia, [1944] CTC 105, le juge MacFarlane au nom de la Cour suprême du Canada, a statué comme suit concernant la portée à donner à l'expression " in connection with ": One of the very generally accepted meanings of "connection" is "relation between things one of which is bound up with or involved in another", or again "having to do with". ... R. (2d) 306 a donné à ces termes une interprétation large: The final question is whether it can be said that the premises were provided "in connection with" the employment. The Shorter Oxford Dictionary defines "connection" as... a "relation between things, one of which is bound up with or involved with another". ...

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 intended to convey some connection between two related subject matters." It is our view, that the phrase "in respect of" is at least as broad, if not broader than the phrase "in connection with". ...

It may not always be easy to decide whether an expense has so arisen but it seems to me that the words "in the course of" in section 11(1)(cb) are not a reference of time when the expenses are incurred but are used in the sense of "in connection with" or "incidental to" or "arising from" and refer to the process of carrying out or the things which must be undertaken to carry out the issuing or selling or borrowing for or in connection with which the expenses are incurred. ... When a corporation enters into a transaction that results in the issuance or sale of shares of its capital stock, the following expenses would be deductible, pursuant to 20(1)(e)(i) of the Act, in computing income for the year in which they are incurred: (a)legal fees in connection with the preparation and approval of a prospectus pertinent to the issuance or sale of shares, units, or interests; (b)accounting or auditing fees in connection with the preparation of reports on financial statements and statistical data for inclusion in, or presentation with the prospectus. ... This position is confirmed in paragraph 13 of IT-341R3 in which we state: "For expenses to qualify under paragraph 20(1)(e), in connection with the issuance or sale of shares, it is not necessary for the taxpayer to obtain additional capital by the issuance or sale of shares. ...

In the case where the interest paid is in connection with a permanent establishment that the Canadian bank has in Australia and such interest will be borne by that permanent establishment, the interest will be deemed to arise in Australia. ... In the case where the interest is in connection with a permanent establishment of the Canadian bank situated in a third state, the default is to source the interest to the state in which the payer is resident. ... Convention sources interest to a third state where the interest is in connection with a permanent establishment the payer has in that state and the interest is borne by that permanent establishment. ...

Principal Issues: Are legal costs incurred in connection with an Ontario Municipal Board hearing regarding the rezoning of farm property from rural to agricultural status deductible under 20(1)(cc)? ... May 12, 2000 XXXXXXXXXX Tax Services Office HEADQUARTERS David Shugar Attention: XXXXXXXXXX 2000-000173 Legal Costs- Farm Pr operty This is in reply to your enquiry of January 5, 2000 concerning the deductibility, under paragraph 20(1)(cc) of the Income Tax Act (the "Act"), of legal costs incurred by farmers, in connection with making representations to the Ontario Municipal Board, supporting the rezoning of their farm property from rural to agricultural status. ... Therefore, legal fees paid, in connection with making representations to the Ontario Municipal Board, relating to a business carried on by a taxpayer, would be deductible in the year paid under paragraph 20(1)(cc) of the Act. ...

Paragraph 3 of IT-99R4 states, "In limited circumstances, legal fees have been held to be deductible where they are incurred in connection with the defence by a taxpayer against a charge of performing illegal actions in the operation of the business or in defense of the day-to-day methods of carrying on business." From the information provided by the taxpayer it appears that in his situation the legal fees were incurred in respect to the charges relating to theft and destruction of property rather than in connection with an alleged performance of illegal operation of his business or in connection with charges relating to the day-to-day methods of carrying on his business. ...

Massicotte, CA, M.Fisc. (613) 590-1116 Attention: William Gonzalez 2003-002274 Internet Fees for Employees Earning Commission Income This is in response to your email of June 9, 2003, requesting our comments in connection with the deduction under paragraph 8(1)(f) of the Income Tax Act (the "Act") of internet fees of a taxpayer employed in connection with the selling of property or negotiating of contracts for the taxpayer's employer. ... Subject to inter alia subsection 8(10) of the Act, where a taxpayer is employed in connection with the selling of property or the negotiation of contracts for his or her employer, paragraph 8(1)(f) of the Act allows the taxpayer to claim a deduction for amounts expended in the year for the purpose of earning the income from such employment (not exceeding the commissions or other similar amounts fixed by reference to the volume of the sales made or the contracts negotiated and received by the taxpayer in the year), provided all the requirements in subparagraphs 8(1)(f)(i) to (iv) are met. ...

The payment is in connection with the planned demolition of the Taxpayer's residence on the reserve? The payment represents compensation for the inconvenience endured by the Taxpayer in being required by the Indian band to move to another house on the reserve Given the foregoing, it is our opinion that a sufficient, indeed a significant, connection can be made between the income in question and the reserve. ... In the absence of the payment's connection to the reserve, it would be necessary to determine how the payment should be characterized in order to ascertain its taxability. ...

Principal Issues: For purposes of the standby charge benefits calculation, is the use by an employee of an emergency vehicle for travelling between the employee's home and usual workplace considered personal use or is the use "in connection with or in the course of the taxpayer's office or employment" where the employee is required by the terms of the employee's employment contract to so use the emergency vehicle. ... For purposes of our response, we have assumed that the emergency vehicles are otherwise only used in connection with or in the course of the employees' office or employment. ... The employees contend that because they are required by the terms of their employment to use the emergency vehicles when travelling between their homes and their usual workplace, those kilometres are driven "in connection with or in the course of the taxpayer's office or employment". ...