Search - connection

In general, payments made by an employer to an employee in connection with a loss or termination of employment, whether or not received as damages or pursuant to an order or judgment of a competent tribunal, would be characterized as a "retiring allowance" as that term is defined in subsection 248(1) of the Income Tax Act (the "Act"). ...

In connection with this holding company function, the foreign affiliate may make non-interest bearing loans (the "NAL Loans") to its banking subsidiaries in order to capitalize them with other than with equity. ...

Paragraph 8502(g) of the Regulations provides that a permissible funding media of a registered pension plan would be an arrangement under which property held in connection with the plan is acceptable to the Minister. ...

Reasons FOR POSITION TAKEN: The wording of the provision authorizes a reassessment as long it is (1) a consequence of a decision on appeal in respect of a particular previous year, (2) completed within the time frame set out in the provision and (3) there is a reasonable connection to the change in the particular year. ...

September 17, 2004 COMPLIANCE PROGRAMS BRANCH HEADQUARTERS International Tax Directorate Income Tax Rulings Directorate Attn: Tim Kuss 2004-008708 We are responding to your memo of July 2004 wherein in you request our view concerning an issue arising in connection with an audit of a client by the Toronto Center TSO. ...

Hamilton Tax Services Office (613) 590-1116 2004-008181 Bankruptcy and Cumulative Net Investment Loss ("CNIL") This is in response to your enquiry of June 17, 2004, in which you request our comments in connection with the effect of a bankruptcy on the calculation of an individual's CNIL balance, as defined in subsection 110.6(1) of the Income Tax Act (the "Act"), for taxation years ending after the date of bankruptcy. ...

The RPP, as holder of a group insurance policy, has received a benefit in connection with the demutualization of XXXXXXXXXX. ...

Under the Agreement, the Taxpayer paid US $XXXXXXXXXX to the Licensor for the right to use the latter's technology in connection with the maintenance, repair and overhaul of XXXXXXXXXX.? ...

In connection with the Amount paid to a retired priest, you have indicated to us that there is no documentation which requires the Amount to be paid. ...

To meet the third condition, the honorarium must be paid to XXXXXXXXXX as a volunteer and his volunteer duties must be in connection with those listed in three above. ...