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Technical Interpretation - Internal

20 August 1990 Internal T.I. 59819 F - Overseas Teaching Assignments

Travel expenses incurred in connection with the  24(1) would, in our view, not satisfy this condition. ...
Technical Interpretation - Internal

18 July 1991 Internal T.I. 911232 F - Foreign Tax Credit

For purposes of determining the foreign tax credit in respect of non-business income tax paid to a particular foreign country: (a)     the amount referred to in paragraph 126(1)(a) is the non-business income tax paid by the individual for the entire calendar year (not just the period or periods therein referred to in paragraph (a) of section 114); (b)     where section 114 is applicable, the numerator in the fraction described in paragraph 126(l)(b) is the foreign non-business income for those periods in the calendar year referred to in paragraph (a) of section 114 and the denominator is      the total net income of the individual from all sources (including recognition of domestic and foreign business income and losses) for those periods in the calendar year referred to in paragraph (a) of section 114 We trust the foregoing is of assistance and return herewith the orange file and all of the materials that you provided to us in connection with this matter. ...
Technical Interpretation - Internal

18 January 1991 Internal T.I. 902447 F - Manufacturing and Processing Deduction

In addition, any of the activities described under the definition of "qualified activities" in section 5202 of the Income Tax Regulations (the "Regulations") such as receiving and storing of raw materials, when performed in connection with manufacturing and processing would themselves be considered as manufacturing and processing.  ...
Technical Interpretation - Internal

4 March 1992 Internal T.I. 9123897 F - W/O Tax on Royalties (Trademarks Design Etc.)

We would agree that rules of instruction and other written material used in connection with such games will probably be considered as "literary work" and therefore subject to copyright. ...
Technical Interpretation - Internal

28 June 2013 Internal T.I. 2013-0474311I7 - Indian - employment income

Specifically, Guideline 4 requires that: a) The employer is resident on a reserve; and b) 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 c) The duties of 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. ... Additionally, none of the duties of employment were in connection with an employer's non-commercial activities carried on exclusively for the benefit of Indians who mostly lived on reserves. ... For the purpose of the proration rule, it is the general position of the CRA that when time spent on the reserve is minimal such that it is considered incidental in relation to the employee's employment duties off reserve, this time will not be considered to have a strong connection to the reserve for purposes of determining the exemption from tax. ...
Technical Interpretation - Internal

1 December 2005 Internal T.I. 2005-0161381I7 - Part XIII Tax

Subject to certain exceptions, subparagraph 212(1)(d)(iii) of the Act provides that every non-resident person shall pay an income tax of 25% on every amount that a person resident in Canada pays or credits, or is deemed by Part I to pay or credit, to the non-resident person as, on account or in lieu of payment of, or in satisfaction of, rent, royalty or similar payment, including, but not so as to restrict the generality of the foregoing, any payment for services of an industrial, commercial or scientific character performed by a non-resident person where the total amount payable as consideration for those services is dependent in whole or in part on the use to be made of, or the benefit to be derived from, those services, production or sales of goods or services, or profits, but not including a payment made for services performed in connection with the sale of property or the negotiation of a contract, Subject to certain exceptions, subparagraph 212(1)(d)(v) of the Act provides that every non-resident person shall pay an income tax of 25% on every amount that a person resident in Canada pays or credits, or is deemed by Part I to pay or credit, to the non-resident person as, on account or in lieu of payment of, or in satisfaction of, rent, royalty or similar payment, including, but not so as to restrict the generality of the foregoing, any payment that was dependent on the use of or production from property in Canada whether or not it was an instalment on the sale price of the property, but not including an instalment on the sale price of agricultural land. ... The postamble of subparagraph 212(1)(d)(iii) of the Act states that the provision does not apply to a payment made for services performed in connection with the sale of property or the negotiation of a contract, neither of which are applicable here. ... In this situation, the relevant portion of the $XXXXXXXXXX per hour payment to the Parent that is a payment for services provided by Parent in connection with the maintenance of the Aircraft, is a payment that is dependent upon Canco's use to be made of the Parent's services provided under the Agreement. ...
Technical Interpretation - Internal

30 November 1997 Internal T.I. 980576B - RELATED GROUP LOSS UTILIZATION SCHEME

We also acknowledge your letters of XXXXXXXXXX and our telephone conversations in connection herewith. To the best of your knowledge, and that of the taxpayers named herein, none of the issues involved in this advance income tax ruling request is under objection or appeal or is being considered by any tax services office or taxation centre of Revenue Canada in connection with any income tax return already filed. ... In connection with the transfer of properties described in paragraph 22 above, XXXXXXXXXX and XXXXXXXXXX will jointly elect in prescribed form within the time limit referred to in subsection 85(6), to have the provisions of subsection 85(1) apply to the transfer. ...
Technical Interpretation - Internal

25 January 2010 Internal T.I. 2009-0319951I7 - Article 15 & definition of permanent establishment

Paragraph 2 of Article 27A provides that "A person who is a resident of a Contracting State" will be deemed to be carrying on a business in Canada through a permanent establishment if the person carries on activities in Canada in connection with exploration or exploitation of the seabed and subsoil and their natural resources in Canada. ... The Canada-Denmark Treaty contains Article 27- Activities in Connection with Preliminary Surveys, Exploration or Extraction of Hydrocarbons. ...
Technical Interpretation - Internal

2 March 2011 Internal T.I. 2011-0392001I7 - Qualifying Period - OETC - 122.3(1)

The employee in this case did not satisfy the requirements of 122.3(1)(b)(i) because he never performed any duties of employment in connection with the contract for Vessel B under which the employer carried on business outside Canada with respect to a qualifying activity. ... Since the contract for Vessel A did not last for a sufficient period of time, any employee who worked only in connection with that contract would therefore not qualify for the OETC. ...
Technical Interpretation - Internal

5 May 2009 Internal T.I. 2009-0316531I7 - Employee Benefits - Discount on Home Upgrades

They import such meanings as "in relation to", "with reference to" or "in connection with". The phrase "in respect of" is probably the widest of any expression intended to convey some connection between two related subject matters. ...

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