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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 eligible purposes that would have qualified for interest deductibility had the capital been borrowed money. ...

One of the conditions requires that as a result of the particular order or decision, some or all of the activities of the eligible entity at, or in connection with, the qualifying property are required to cease. ...

Briefly, in the context of these rulings, we note that under the "active trade or business" test provided under Article XXIX-A(3), a resident of the US (US Person) deriving an item of income from Canada (Canadian-source income) would generally be entitled to benefits with respect to that income if: i. the US person, or a person related to the US person, is engaged in an active trade or business in the US; ii. the Canadian-source income in question is derived in connection with, or is incidental to, that US trade or business; and iii. the size of the active trade or business in the US is substantial relative to the activity in Canada that gives rise to the Canadian-source income for which benefits are sought. In the specific situations considered by IT Rulings, the first two criteria noted above, i.e., (i) active trade or business in the US and (ii) Canadian-source income derived in connection with or incidental to the US business, were clearly satisfied based on the facts provided. ...

In general, those two conditions require a connection between the specified right and the particular funding arrangement. ... In general, those conditions require a connection between the funder debt and the particular funding arrangement. ...

The loan is incurred in connection with US LLC 2’s real estate operations in Canada, which constitute its permanent establishment in Canada, and the interest on the loan is borne by the permanent establishment. ... In each of the three scenarios above, interest paid by US LLC 2 shall be deemed to arise in Canada pursuant to Article XI(4) of the Treaty on the basis that US LLC 2 has a permanent establishment in Canada in connection with which the indebtedness was incurred, and such interest is borne by such permanent establishment. ...

Income Tax Convention exempts such payments made to a U.S. resident from Canadian withholding tax except where the information is provided in connection with a rental or franchise agreement. ... (b) Would a licence of information concerning industrial, commercial or scientific experience combined with a licence of computer software for use in dealing with the information be considered to be "in connection with a rental agreement"? ... (b) gain, it is a question of fact whether or not such an arrangement would be considered to be "in connection with a rental...agreement". ...

That provision was introduced in connection with the elimination of the $100,000 lifetime capital gains exemption and permitted certain personal trusts to elect to have a deemed disposition of capital property on February 22, 1994. ...

While considering this situation, we noted that USco also had another Canadian subsidiary providing services to USco in connection with marketing and sales support activities for USco's development and expansion of its user, advertiser and software developer base in Canada. ...

3) Should there be a distinction between an application that requires a connection to the internet and an application that does not? ...

Fees earned by a taxpayer for acting in the capacity of executor in the course of business form part of the business income of the taxpayer, and expenses incurred in this connection are deductible in the usual way in computing such income, to the extent they are not recoverable from the funds of the estate. ...