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What is the current CRA work situation in connection with the conduct of international audits and requests for foreign based information? ...

(which is not normally the case where the Partnership is merely holding shares or interests in a wholly-owned subsidiary), (ii) the Loan was incurred in connection with such permanent establishment, and (iii) the interest paid on the Loan was borne by such permanent establishment. ...

In particular, paragraph 3 provides that treaty benefits may be available to a US resident with respect to income derived from Canada, provided that the income is derived in connection with, or is incidental to, the active conduct of a trade or business (other than certain investment businesses) carried on in the US by the US resident, or a person related to the US resident, and provided that the US trade or business is substantial in relation to the activity carried on in Canada giving rise to the income. ...

For the purposes of subparagraph 6(1)(b)(vii.1), subparagraph 6(1)(b)(x) of the Act deems an allowance received in a taxation year by an employee for the use of a motor vehicle in connection with, or in the course of, an office or employment not to be a reasonable allowance if it is not calculated solely by reference to the number of kilometres for which the vehicle was so used in the year. ...

A T3 trust return serves to report not only information about the reporting trust, but also additional information, such as that affecting the taxation of persons (for example, beneficiaries or settlors) having some connection to the trust. ...

Questions: (a) Does the CRA agree that subsection 148(7) is not applicable on the distribution of a life insurance policy in connection with the winding-up of a corporation in circumstances such that subsection 88(1) is applicable? ...

Dodd Rick Gallichan 957-8954 Information Returns Section 982945 Partnership Information Return- Late Filing Penalty We are writing in reply to your November 12, 1998 facsimile transmission concerning the XXXXXXXXXX (the “Partnership”) and the late filing penalty assessed in connection with its annual partnership information return. ...

However, it would appear that under Revenue Canada’s new policy with regard to the real-time auditing of large corporations, the Tax Services offices are regularly consulted by these companies for an opinion on specific issues in connection with planned transactions. ...

In connection with these requests we reconsidered our previous opinion, our response to question 33 of the Revenue Canada Round Table at the 1988 Canadian Tax Conferencei, and the relevant jurisprudence and literature. ...

The CRA will publish its views in reference to this matter along with details of its findings in connection with the issues raised in Questions 2 and 5 of the IFA Roundtable in an Income Tax Technical News article when our review is complete. ...