Search - connection

As was discussed in our above noted telephone conversation, we would consider a request for a new advance income tax ruling in connection with the above mentioned matter provided that a full disclosure of the facts, proposed transactions and purpose of the proposed transactions in respect of new ruling request is made, as set out in Information Circular 70-6R. ...

As such, the CCA classes of assets in the a terminal should be determined on an individual basis giving consideration to both the specific use that is made of the asset and the degree of connection to or integration with other assets used for an identifiable function in which the asset is used.  ...

Harding   (613) 957-3499 December 4, 1989 Dear Sirs: This is in reply to your letter of November 15, 1989 wherein you requested clarification as to whether or not the retirement compensation arrangement ("RCA") provisions of the Income Tax Act (the "Act") 24(1) The RCA provisions generally apply when any "contributions" (payments) are made to another person, including a bank, trust company or other investment dealer, in connection with the payment of retiring benefits. ...

Consequently, we are not prepared to respond definitively to questions raised in connection with a portion of such an arrangement without examining the entire settlement document. ...

In this connection, we draw your attention to paragraphs 3 and 12 of that Bulletin concerning property designated for a year after 1981 by a related person, such as your spouse or child, and land in excess of 1/2 hectare. ...

" (iii)       In connection with the statement that IT-178R2 will be amended, we understand that the Publications Division has not been informed of this adverse decision. ...

A statement as to whether any of the issues involved in the ruling request are, to the best of your client's knowledge, being considered by a District Office and/or Taxation Centre in connection with a tax return already filed, or if any of the issues ore under objection or appeal. 3.      ...

The reference in paragraph (2) of Article 19 to "services rendered in connection with a business carried on by a Contracting State... ...

As the other listed allowances are received in connection with the training allowances,and are, in a sense, themselves training allowances, they are exempt as well, providing of course, the recipient receives the training allowance as exempt income. ...

It may not always be easy to decide whether an expense has so arisen but it seems to me that the words "in the course of" in section 11(1)(cb) [the predecessor to paragraph 20(1)(e) of the Act] are not a reference to the time when the expenses are incurred but are used in the sense of "in connection with" or "incidental to" or "arising from" and refer to the process of carrying out of the things which must be undertaken to carry out the issuing or selling or borrowing for or in connection with which the expenses are incurred. ...