Search - connection

In connection with the XXXXXXXXXX employment, the individual moved from XXXXXXXXXX and claimed moving expenses of $XXXXXXXXXX (the individual earned employment income of $XXXXXXXXXX prior to leaving Canada). ... In connection with the position, the Individual moved from XXXXXXXXXX and claimed moving expenses of $XXXXXXXXXX which were allowed when the Individual’s 1996 return was assessed. ...

Furthermore, it is our view that the term "in connection with television" as used in subsection 212(5) is very broad and would apply to videotapes destined for private home use. ... Income Tax Convention; the said payments representing copyright royalties in respect of the reproduction of any literary, dramatic, musical or artistic work other than in respect of motion pictures and works on film, video tape or other means of reproduction for use in connection with television broadcasting. ...

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. ...

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. ...

They import such means 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. ...

No evidence of any connection between the assumption by the corporate taxpayer of the mortgage and the acquisition by it of the common shares. ... While the corporate taxpayer did acquire shares of public corporations in an earlier transaction and as consideration issued corporate indebtedness to its shareholder, we are not aware of any evidence that there was any connection between the subsequent assumption by the corporate taxpayer of its shareholder's mortgage and the acquisition of any property, including the public shares. ...

Reasons: In such case there is a direct causal connection between the investment in the foreign affiliate and the FAPI income of the foreign affiliate. ... Therefore we would like to clarify that in our view, the provisions of subparagraph 152(4)(b)(iii) of the Act will extend the period during which an assessment or reassessment may be made provided it is established that there is a causal connection [i.e. it can reasonably be regarded as relating to, as required by subsection 152(4.01)] between the FAPI earned by the CFA and the taxpayer's investment in the shares of that affiliate and provided the shares were acquired by the taxpayer directly from the CFA. ...

Our Comments One of the conditions for a taxpayer to qualify for the OETC is that he has to perform "all or substantially all of the duties of his employment outside Canada in connection with a contract under which the specified employer carried on business outside Canada" with respect to certain qualified activities. ... Even if XXXXXXXXXX were considered to be carrying on business outside Canada under a contract with respect to qualified activities (which in our view is not the case), after reviewing the information you provided, we agree with you that not all or substantially all of the duties performed by the taxpayer was in connection with such a contract. ...

Comments In general terms, an RCA is defined in subsection 248(1) of the Income Tax Act (the "Act") as a plan or arrangement under which contributions are made by an employer to another person (referred to as a custodian) in connection with benefits to be provided to employees on or after the employee's termination of services. ... In such a case, we may question whether or not the arrangement is, in fact, an RCA because it would be questionable whether the employer contribution would be made in connection with benefits to be received on the employee's termination of services. ...

However, the CCRA considers the word "lodge", for this purpose, to mean an inn or resort hotel, particularly one that is a centre for recreational activities, as well a dwelling occupied on a seasonal basis in connection with particular activities, such as hunting, fishing, or heli-skiing. ... X unless you have some evidence that their business connections to the company are merely incidental or their connection to Mr. X is more of a social connection (i.e. the business associates are merely personal friends of Mr. ...