Search - connection

Filter by Type:

Results 381 - 390 of 487 for connection
Technical Interpretation - Internal

20 March 2002 Internal T.I. 2002-0126537 - Article XV(2); Employee Stock Options

In the same taxation year, Canco granted stock options to the taxpayer in connection with his employment exercised in Canada.? ...
Technical Interpretation - Internal

30 September 2002 Internal T.I. 2002-0152107 F - BRANCHEMENT A DES SERVICES PUBLICS

L'alinéa 62(3)h) de la Loi prévoit que les frais de déménagement comprennent les dépenses engagées pour le coût de connexion et déconnexion des services publics. ...
Technical Interpretation - Internal

7 October 2002 Internal T.I. 2002-0159947 - MEALS & ENTERTAINMENT EXPENSES

Among other things, subparagraph 6(1)(b)(vii) applies where a reasonable allowance for meal expenses is received by an employee (other than one employed in connection with the selling of property or negotiating of contracts for the employer) and the allowance is received for travelling away from the municipality and the metropolitan area (if there is one) where the employer's establishment, at which the employee ordinarily worked or to which the employee ordinarily reported, is located, and the travelling is done in the performance of the duties of the office or employment. ...
Technical Interpretation - Internal

26 May 2000 Internal T.I. 1999-0009037 - Income Capital Gain Ireland Article VI

In connection with this, it is our understanding that, in many CSs such as the United States, the taxation is based on the gross capital gains. ...
Technical Interpretation - Internal

20 April 1999 Internal T.I. 9902707 - CHILD SUPPORT PAYMENTS

In connection with this issue, Individual A has indicated that Individual C reported the Maintenance as income in 1996 and 1997 under the relevant provisions of the Act. ...
Technical Interpretation - Internal

17 May 2021 Internal T.I. 2020-0870041I7 - CERS - Meaning of Qualifying Property

While common-law principles would establish that only one property exists when something built on land has a substantial connection with it, and the purpose of that construction is to effect a permanent improvement upon the land, the component parts of the property (for instance, land and building) may, nonetheless, be considered separately for tax purposes in certain situations. ...
Technical Interpretation - Internal

14 August 1990 Internal T.I. 901579 F - Redemption of Shares Subsection 84(3) Deemed Dividends

In this connection, we agree that it would also be reasonable to reduce the income taxes on the $200,000 as otherwise determined by a pro rated portion (based on the number of days in the 1989 stub period as a proportion of the total number of days in Co.'s 1989 taxation year of 16% of the least of the amounts referred to in subsection 125(1) of the Act, but subject to subsections 125(2) and (3) of the Act. 2.      ...
Technical Interpretation - Internal

6 April 1990 Internal T.I. 59047 F - Withholding Tax - Contracts with U.S. Corporation for Maintenance of Computer Software and Hardware

It is our position that the following two conditions must be met in order for payments for any services, including a hotline service, provided in connection with the use of computer software not to be considered part of the software licence fee which is subject to Part XIII tax: (i)     The acquisition of the services should be optional.  ...
Technical Interpretation - Internal

21 August 1991 Internal T.I. 9027867 F - Active Business Income

The fact that a corporation, carrying on an active business and holding certain property (i.e. investments) unrelated to the business, uses the income from property in connection with the operation of the active business does not mean that the property is "incident to or pertains to" the active business. ...
Technical Interpretation - Internal

7 August 1990 Internal T.I. 74569 F - UCC Class 10 - Separate Businesses

He stated at page 89      "I think the real question is, was there any inter-connection, any interlacing, any inter-dependence, any unity at all embracing those two businesses;". ...

Pages