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Results 391 - 400 of 488 for connection
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;". ...
Technical Interpretation - Internal
13 January 2023 Internal T.I. 2022-0956531I7 - Tax treatment of tuition reimbursements
More specifically, the total amount of scholarship income may be eligible for a full scholarship exemption (and therefore, not subject to income tax), if the scholarship or bursary is received in connection with the recipient’s enrolment in an educational program in respect of which they are considered a full-time (FT) “qualifying student”* in the year, in the immediately preceding tax year or in the following tax year. * A “qualifying student” for a month in a tax year includes an individual who, in the month, is enrolled in a “qualifying educational program” (QEP) as a FT student at a “designated educational institution” (DEI). ...
Technical Interpretation - Internal
12 October 2010 Internal T.I. 2010-0367611I7 - Cross Currency swap - Income or Capital
PlacerDome Canada Limited, 2006 SCC 20) have confirmed that whether an activity constitutes hedging depends on sufficient inter-connection or integration with the underlying transaction. ...
Technical Interpretation - Internal
19 November 2012 Internal T.I. 2012-0433201I7 - Legal fees incurred re: job reinstatement
Cases involving the deductibility of legal fees incurred to establish a right to a promotion or a raise or where the claimant is seeking financial compensation in connection with allegations of unlawful or wrongful acts by an employer remain distinguishable. ...
Technical Interpretation - Internal
10 November 2014 Internal T.I. 2014-0532801I7 - film or video production services tax credit
In Rulings document 2000-0025183 (XXXXXXXXXX, 2000), the following activities were not considered to detract from a conclusion that production services activities were the taxpayer's primary business on the basis that they were provided in connection with production services: XXXXXXXXXX. ...
Technical Interpretation - Internal
27 June 2011 Internal T.I. 2011-0403761I7 - Growing Forward
However, some portion of this compost material is applied directly by Aco onto its fields in connection with its own sod growing activities. ...
Technical Interpretation - Internal
23 March 2010 Internal T.I. 2009-0348551I7 - Accumulated Profits
In connection with this use, the purpose test will be met if the borrowed money replaces capital (contributed capital or accumulated profits) that was being used for purposes that would have qualified for interest deductibility had the capital been borrowed money (eligible purposes). ...
Technical Interpretation - Internal
29 July 2016 Internal T.I. 2015-0600941I7 - Share Based Deferred Compensation - Section 7
Canco is billed by USco for the costs incurred by USco in connection with the common shares issued at a discount to Canco’s employees. ...
Technical Interpretation - Internal
24 June 2009 Internal T.I. 2009-0324851I7 - Beneficial Ownership - Residential Property
., purchase and sale agreement and amendments thereto), and the ancillary contracts in connection with the sale (i.e., listing contract with the Realtor, bridge financing contract with the Bank, and the legal services with the Rep who provided a final reporting letter and statement of trust accounts) consistently name Brother as, and thereby represent him to be, owner of the Old Property. ...
Technical Interpretation - Internal
14 April 2008 Internal T.I. 2008-0271861I7 - Taxation of payment to Nisga'a citizen
On the other hand, if the payment was made out of the income of the trust, there is no inherent connection to a reserve. ...