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Due to the time period (XXXXXXXXXX) in which XXXXXXXXXX received the amounts outlined in item 4 of the conclusion to the December 15, 1995, letter from XXXXXXXXXX, the tax status of certain amounts paid to or on behalf of XXXXXXXXXX pursuant to Part II section 9 of the TARs has been considered in connection with our review of the tax treatment of comparable amounts under the Treasury Board Foreign Service Directives. ...

Humenuk 957-8953 Attention: Dave Harron 963837 XXXXXXXXXX Disability Tax Credit This is further to your memorandum of November 15, 1996, in connection with the above-noted taxpayer. ...

In relation to these two requirements, it is our general view that a student needs to be enrolled in connection with the course or program in respect of which tuition has been paid. ...

In connection with the comments in the above paragraph, we are also mentioning that a PHSP must be in the nature of insurance and, in that regard, must contain the basic elements set out in paragraph 3 of IT- 339R2. ...

We also note that the above comments are consistent with the following explanatory note released by the by the Department of Finance (May, 1991) in connection with the amendment: This paragraph is amended to clarify that, for this exemption to apply, the food, beverages or entertainment must be generally available to all employees at a particular location of the employer and consumed or enjoyed by such employees. ...

In connection with the above comments, we have also considered the recent decision rendered by the Federal Court of Appeal (FCA) in the Augart case (a copy of this case has been included for your reference.). ...

It seems reasonable to assume that they would do so since they will presumably not be entitled to deduct CCA in respect of the vehicle (because paragraph 18(1)(c) of the Act prohibits any deduction in respect of an outlay or expense used to earn exempt income or in connection with property that is used to earn exempt income) and they will not realize any proceeds on the disposition thereof if and when the Ministry recovers the property without compensation upon the termination of the contracts. ...

A. 4Marital status determinations are normally made as at a particular time, in connection with an event or transaction taking place. ...

Proposed Law Under proposed subsections 207.6(5) and (5.1), the contributions will be subject to the RCA rules if made to a paragraph (l) plan and if the contributions may reasonably be considered to have been made in respect of services that were primarily rendered in Canada or were rendered in connection with a business carried on by the employer in Canada (or a combination of such services). ...

In a telephone conversation of March 29, 1995 with XXXXXXXXXX Section 122.3 of the Act provides, amongst other things, that an individual resident in Canada in a taxation year who, throughout any period of more than six consecutive months that commenced in the year or a previous year, was employed by a specified employer (within the meaning assigned by subsection 122.3(2) of the Act), and performed all or substantially all of his or her duties of employment outside Canada in connection with a contract under which the specified employer carried on a business outside Canada with respect to "any construction, installation, agricultural or engineering activity", the individual will be eligible to claim the OETC under subsection 122.3(1) of the Act. ...