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Technical Interpretation - Internal

4 March 1998 Internal T.I. 9722576 - employer provided automobiles

In these circumstances, the office would be considered a regular place of work of the individual and travel from this regular place of work (the individual’s residence) to another location, other than the employer’s, in connection with the individual’s employment duties would be business related and not personal travel. ...
Technical Interpretation - Internal

16 April 1998 Internal T.I. 9732407 - 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

27 May 1998 Internal T.I. 9731957 - WRONGFUL DISMISSAL DAMAGES

The Bulletin also clarifies that payments made to an employee as general damages in connection with a loss or termination of employment will normally be treated as retiring allowances. ...
Technical Interpretation - Internal

18 June 1998 Internal T.I. 9807757 - PRINCIPAL RESIDENCE - 1/2 HECTARE

We would also note, that it is our general view that the fact that an individual makes use of more than 1/2 hectare of land in connection with a particular lifestyle does not, in itself, mean that it is necessary for the use and enjoyment of the housing unit as a residence. ...
Technical Interpretation - Internal

6 May 1998 Internal T.I. 9810067 - DEDUCTIBILITY OF LEGAL FEES

If you wish to refer any documentation or other information in connection with this enquiry in order that we may provide an interpretation of the Act in the circumstances of this case, or if we can be of any further assistance, please contact the writer. ...
Technical Interpretation - Internal

24 April 1998 Internal T.I. 9801607 - FILING - NON-RESIDENT CORPORATION

While a non-resident corporation that does not have and has never had any connection with Canada may not be subject to the requirement under subsection 150(1) to file a return, all non-resident corporations that carried on business in Canada, disposed of taxable Canadian property or had other income of the kind referred to in section 115 of the Act, must comply with subsection 150(1). ...
Technical Interpretation - Internal

17 June 1998 Internal T.I. 9811566 - ART XXIX B OF U.S. TREATY - XXXXXXXXXX

Income Tax Convention- XXXXXXXXXX We are writing in reply to your memorandum of May 1, 1998 in which you requested our advice in connection with an enquiry from XXXXXXXXXX with respect to the credit provided under Article XXIX B of the Canada-U.S. ...
Technical Interpretation - Internal

22 March 1994 Internal T.I. 9402046 - CENTRE OF VITAL INTERESTS - XXXXXXXXXX EMPLOYEE (4093- U5-100-4)

The permanent home test and the centre of vital interests test are similar in that they are attempting to settle the matter on those more meaningful or significant connections to a state as opposed to residence based merely on time or length of stay. ...
Technical Interpretation - Internal

21 April 1994 Internal T.I. 9400177 - FAMILY ALLOWANCE RECEIVED IN 1993

In connection with these comments, subsection 56(5) provides that "an individual who is deemed by subsection (6) or (7) to have supported in a particular month of a taxation year a person in respect of whom a family allowance... is paid for the particular month shall include in computing his income for the year an amount of such an allowance received... ...
Technical Interpretation - Internal

9 June 1994 Internal T.I. 9405947 - SETTLEMENT OF DAMAGES

The amount appears to have been paid in exchange for XXXXXXXXXX right to take legal action in connection with the possible claims under the policy. ...

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