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Comments Paragraph 149.1(4)(d) of the Act authorizes the Minister to revoke the registration of a private foundation that has “since June 1, 1950, incurred debts, other than debts for current operating expenses, debts incurred in connection with the purchase and sale of investments and debts incurred in the course of administering charitable activities.” ...

It is the Department's view that paragraph 18(1)(1) would not have application to deny an outlay or expense in connection with a vessel essential to the business operations, all or substantially all the use of which is for business purposes....      6.  ...

Your request follows a meeting held on November 30, 1989, at which Jack Szeszycki of this Division attended, between representatives of Revenue Canada, Taxation, National Health and Welfare and the Background 24(1) Generally, individuals that will be entitled Co assistance under the Wage Policy are already receiving some level of social assistance in connection with their disability.  ...

Such a computation is not made where, as here, the land in question was not used or held in connection with the generation of income, whether from business or from the property itself. ...

Accordingly, the independent dealer in receipt of the benefit would include the amount of the benefit (i.e. equal to the rent amount paid by the operating company) in his income. 5)     Because of concerns in connection with U.S. estate tax, the Canadian individual would incorporate a new Canadian company (Newco) wholly owned by him, to acquire the recreational property. ...

It is not our practice to request a legal opinion in connection with a technical interpretation request. ...

The individual (19)(1) must be employed by a person who is a specified employer and must have performed all or substantially all  the duties of his employment in one or more countries other than Canada in connection with a contract under which the specified employer carried on business in such other country or countries with respect to any construction, installation, agricultural or engineering activity.  ...

We also are of the opinion that the word "made" is the correct verb for the noun "contribution", whereas "paid" should be used in connection with "amount"; therefore, the difference in wording between the two provisions results from the choice of noun and not from any other legislative intent as alleged by the accountants. (2)      if the (amounts) were paid now, when would they be deductible. ...

Dependency and Indemnity Compensation We are writing in reply to your email of May 30, 2022 in connection with the treatment under the Income Tax Act (the “Act”) of payments of Dependency and Indemnity Compensation (DIC) benefits received by a Canadian resident taxpayer from the United States Department of Veterans Affairs. ...

Specifically, USCo granted to Canco an exclusive license to (i) use trade-marks in connection with the operation of those outlets in Canada, (ii) to use and to sub-franchise proprietary information, know-how and the franchise system in connection with the operation of those outlets, and (iii) to enter into agreements to permit sub-franchisees to use the aforementioned trademarks, proprietary information, know-how and franchise system in connection with the operation of outlets in Canada. ... This is evident from the various dictionary definitions of the word "royalty" when used in connection with a sum payable. ... Treaty exempts payments for the use of or the right to use information of this type, the exemption does not apply if the information is provided in connection with a franchise agreement. ...