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In connection with this use, the purpose test will be met if the borrowed money replaces capital (contributed capital or accumulated profits) that was being used for eligible purposes that would have qualified for interest deductibility had the capital been borrowed money. ...

There is a logical connection between the income from ULC and the U.S. taxes paid by Taxpayer because if Taxpayer did not own such shares, no U.S. taxes would have been paid. ...

Our Comments Subject to a number of exceptions, paragraph 6(1)(a) of the Act includes in employment income the value of benefits “of any kind whatever” that are received or enjoyed by an employee in connection with his or her office or employment. ...

October 31, 2011 TORONTO CENTRE TSO HEADQUARTERS Large File Audit Income Tax Rulings Directorate Attention: Caspar Verre Sylvie Danis (613) 957-3496 2011-042191 XXXXXXXXXX Part I.3 Tax We are writing in response to your memo dated September 14, 2011 wherein you request additional guidance with respect to the application of paragraph 181.2(4)(a) of the Income Tax Act (the "Act") in connection with the audit of XXXXXXXXXX taxation year. ...

In connection with this use, the purpose test will be met if the borrowed money replaces capital (contributed capital or accumulated profits) that was being used for eligible purposes that would have qualified for interest deductibility had the capital been borrowed money. 1.49 Contributed capital generally refers to funds provided by a corporation's shareholders to commence, or otherwise further, the carrying on of its business. ...

Reasons: For elected municipal officers, subsection 81(3) of the Act provides an exception to the general rule that benefits or allowances paid in connection with an office or employment are taxable. ...

Our views concerning the taxation of income received by a PDF are outlined below: In order to qualify for the full scholarship exemption under subsection 56(3) of the Act, first, the amount must be properly included in income under paragraph 56(1)(n) of the Act and, second, the amount must be "received in connection with the taxpayer's enrolment in an educational program in respect of which an amount may be deducted under subsection 118.6(2)" (i.e., the individual must be able to claim the education tax credit). ...

There must be a connection between the benefit and the employee’s employment. ...

Once mounted, plumbing and electrical connections would be installed and a skirting arranged around the understructure. ...

For the 2006 and subsequent taxation years, scholarships, fellowships and bursaries will be excluded from income if received in connection with an educational program for which the individual may claim the education tax credit. ...