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Technical Interpretation - Internal

14 February 2008 Internal T.I. 2007-0256401I7 F - Vente d'un surplus actuariel

The phrase "in respect of" has been described as "the widest of any expression intended to convey some connection between related subject matters": Nowegijick v. ...
Technical Interpretation - Internal

6 May 2005 Internal T.I. 2005-0117751I7 - Foreign Currency Hedging Losses - Resource Profits

In addition, it is our opinion that the existence of the Hedging Policy described in paragraph 2 above provides support for this connection and that the terms of the Policy do not suggest that the Company was involved in a speculative activity separate from its business of producing XXXXXXXXXX. ...
Technical Interpretation - Internal

12 March 1998 Internal T.I. 9733567 - PARTS I.3 AND VI - MEANING OF "ACCEPTED"

This issue has arisen in connection with an audit of the above-noted financial institution. ...
Technical Interpretation - Internal

10 June 1998 Internal T.I. 9808707 - TRAVEL PROMO AND SALARY EX FOR INVEST CORP

Rather, it is the connection between those expenses and the income earning process which is relevant for the purpose of paragraph 18(1)(a), and it is the nature of the expenses which is relevant for the purpose of paragraph 18(1)(b) of the Act. ...
Technical Interpretation - Internal

23 September 1998 Internal T.I. 9822230 - RESIDENCE UNDER AN INCOME TAX CONVENTION

A decision to the contrary would have allowed treaty benefits to accrue to those who had quite modest connections with the United States. ...
Technical Interpretation - Internal

24 September 1998 Internal T.I. 9815597 - XXXXXXXXXX INDIAN BAND

Given the information you provided it appears unlikely that Guideline 4 could be met, as the activities of XXXXXXXXXX would not meet the requirement that the duties of employment be in connection with the non-commercial activities of the employer. ...
Technical Interpretation - Internal

1 November 1994 Internal T.I. 941600A - COST OF LIVING PAYMENTS

In this connection, we also refer you to the comments on living expenses set out on page 6184 of the Phillips decision. ...
Technical Interpretation - Internal

12 October 1995 Internal T.I. 9524630 - BENEFITS FROM RELOCATION INDUCEMENTS

In this connection, reference should be made to the comments on living expenses set out on page 6184 of the Phillips decision (94 DTC 6177). ...
Technical Interpretation - Internal

25 August 2003 Internal T.I. 2003-0015917 - manufacturing and processing profits

Given, however, the provisions merely refer to sale, it cannot be concluded that a definition other than that which follows from common law and sale of goods legislation was envisioned. [36] For the taxation years in issue, approximately 75 per cent of the asphalt produced by the Will-Kare's plant was supplied in connection with Will-Kare's paving services. ...
Technical Interpretation - Internal

15 October 2004 Internal T.I. 2004-0074201I7 - Deductibility of Support Amounts

Calgary Tax Services Office (613) 590-1116 2004-007420 Deductibility of Support Amounts This is in response to your enquiry of April 27, 2004, in which you seek our comments in connection with the deductibility under paragraph 60(b) of the Income Tax Act (the "Act") of support amounts paid by XXXXXXXXXX (Mr.A) during the years 1997 and 1998. ...

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