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Technical Interpretation - Internal

24 September 2007 Internal T.I. 2007-0242181I7 - Bursary for theological studies in the US

Where the bursary is received in connection with the individual's enrolment in an educational program eligible for the education tax credit, the full amount will be exempt. ...
Technical Interpretation - Internal

31 May 2006 Internal T.I. 2006-0177961I7 - Non-Competition Payments

However, in the situation described, it appears that pursuant to the SPA and the NCA made in connection with the sale of the Business, XXXXXXXXXX received the NCP from an arm's length purchaser as consideration for granting a covenant not to compete. ...
Technical Interpretation - Internal

7 December 2005 Internal T.I. 2005-0155071I7 - Employment Income of a Status Indian

It also requires that the employer be an Indian band that has a reserve, or a tribal council representing one or more Indian bands that have reserves, or an Indian organization controlled by one or more such bands or tribal councils, if the organization is dedicated exclusively to the social, cultural, educational, or economic development of status Indians who for the most part live on reserves, and that the duties of the employment are in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserve. ...
Technical Interpretation - Internal

19 January 2018 Internal T.I. 2017-0721641I7 - Thin Cap.-Retained Earnings-Other Income (Loss)

In connection with the Taxation Years, the Taxpayer reported an OCI debit balance (i.e. an accumulated other comprehensive loss) in its legal entity financial statements that were prepared in accordance with U.S. ...
Technical Interpretation - Internal

16 April 1998 Internal T.I. E9732407 - Indian Act Income Tax Exemption

It also requires that the employer is an Indian band which has a reserve, or a tribal council representing one or more Indian bands which have reserves, or an Indian organization controlled by one or more such bands or tribal councils, if the organization is dedicated exclusively to the social, cultural, educational, or economic development of Indians who for the most part live on reserves; and that the duties of the employment are 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

8 April 1997 Internal T.I. 9700607 - MEDICAL EXPENSE - SOCIAL WORKER

The functions of social work include helping people to develop individual and collective social problem-solving skills; enhancing self-determination and the adaptive and developmental capacities of people; advocating, promoting and acting to obtain socially just distribution of societal resources and facilitating social connections between people and their societal resources. ...
Technical Interpretation - Internal

8 July 1997 Internal T.I. 9717116 - EDUCATION CREDIT - FULL-TIME ENROLMENT

" In addition, the definition of "qualifying educational program" specifically excludes a program of study taken in connection with, or as part of, the duties of the student's employment, and during a period for which the student is receiving income for that employment. ...
Technical Interpretation - Internal

29 May 1997 Internal T.I. 9703367 - INCOME FROM EMPLOYMENT OF INDIANS - WHETHER EXEMPT

It also requires that the employer is an Indian band which has a reserve, or a tribal council representing one or more Indian bands which have reserves, or an Indian organization controlled by one or more such bands or tribal councils, if the organization is dedicated exclusively to the social, cultural, educational, or economic development of Indians who for the most part live on reserves; and that the duties of the employment are 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 September 1997 Internal T.I. 9707617 - MISSING PERSONS PRESUMED DEAD BY COURT

In this case, it appears that the order was made in connection with the application by XXXXXXXXXX to be appointed as trustee of the estate. ...
Technical Interpretation - Internal

29 September 1997 Internal T.I. 9724247 - INDIAN ACT EXEMPTION GUIDELINE 1 AND PRORATION RULE

Principal Issues: (1) Status Indian employee requesting exemption, by virtue of Proration Rule to Guideline 1, of duty performed off reserve but in connection to work performed on reserve. ...

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