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Income Tax Folio S4-F3-C2, Provincial Income Allocation, 30 January 2024-- summary under Subsection 402(5) Summary Under Tax Topics- Income Tax Regulations- Regulation 402- Subsection 402(5) CRA broad interpretation of Reg. 402(5) exclusion 2.23 Subsection 402(5) of the Regulations provides that for purposes of subsection 402(3), gross revenue of a corporation does not include interest on bonds, debentures or mortgages, dividends on shares of capital stock, or rentals or royalties from property that is not used in connection with the principal business operations. 2.24 In Provincial Income Allocation Newsletter No. 1 the CRA confirmed that a broad interpretation of the excluded amounts is appropriate for the purposes of Part IV of the Regulations. Under such a broad interpretation, interest on promissory and other notes, bankers’ acceptances, intercompany loans, certificates, guaranteed investment certificates, and any unsecured debt instruments or other similar obligations would also be excluded from the gross revenue of a corporation. 2.25 In addition, the reference in subsection 402(5) to “that is not used in connection with the principal business operations of the corporation” refers only to “rentals or royalties from property” and not to the other items enumerated in that subsection. ...

GST/HST Memorandum 4.5.3 “Exports – Services and Intellectual Property” June 1998-- summary under Paragraph 7(d) Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part V- Section 7- Paragraph 7(d) Principles re "in respect of" exclusion Determining connection between service and property 46. The following guidelines help in determining whether the connection between the service and the real or tangible personal property is sufficient for the service to be "in respect of" the property for purposes of paragraphs 7(d) and (e) and paragraphs 23(b) and (c) of Part V of Schedule VI. purpose or objective (a) Was the service designed, developed or undertaken to fulfil or serve a particular need or requirement arising from or relating to the property? ... If some object comes between the service and the property, the connection becomes more remote. ...

P-169R Meaning of in Respect of Real Property Situated in Canada and in Respect of Tangible Personal Property that is Situated in Canada at Time the Service is Performed, for Purposes of Schedule VI, Part V, Sections 7 and 23 to the Excise Tax Act-- summary under Section 23 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part V- Section 23 "In respect of" criteria The following guidelines will be applied by the Department to aid in the determination of whether the connection between the service and the real or tangible personal property is sufficiently direct for the service to be "in respect of" the property for purposes of Schedule VI, Part V, sections 7 and 23: a) Was the service designed, developed or undertaken to fulfil or serve a particular need or requirement arising from or relating to the property? ... If some object comes between the service and the property, the connection becomes increasingly remote. ...

In such a case, there is no need to re-document the account holder as long as: the appropriate due diligence requirements have been carried out, or are in the process of being carried out, for the original account; the opening of the new account does not require the provision of new, additional or amended client information; with respect to an account subject to AML/KYC Procedures, the financial institution is permitted to satisfy those procedures for the new account by relying on the procedures performed in connection with the original account; and when a threshold has been applied in connection with the preexisting individual account, the financial institution’s computerized systems are able to link the new account to the original account held by the account holder and allow the account balances or values to be aggregated. ...

GST/HST Notice No. 324, Proposed Amendment Addressing Mining Activities in respect of Cryptoassets, February 2023-- summary under Subsection 188.2(2) Summary Under Tax Topics- Excise Tax Act- Section 188.2- Subsection 188.2(2) Denial of ITCs by virtue of ss. 188.2(2) and (3) (under “Eligibility for ITCs”) Subject to the exclusion in proposed subsection 188.2(5), to the extent that a person acquires, imports or brings into a participating province property or a service for consumption, use or supply in the course of, or in connection with, mining activities of the person, the person is deemed to have acquired, imported or brought into the participating province, as the case may be, the property or service for consumption, use or supply otherwise than in the course of commercial activities of the person. ... In addition, if a person at any time consumes, uses or supplies property or a service in the course of, or in connection with, mining activities of the person, that consumption, use or supply is deemed to be otherwise than in the course of commercial activities of the person in accordance with proposed subsection 188.2(3). ...

.- Q.51-- summary under Subsection 49(1) Summary Under Tax Topics- Income Tax Act- Section 49- Subsection 49(1) Warrants issued in connection with a "poison pill" arrangement are a form of option and, therefore, are subject to the usual option rules. ...

.- Q.14-- summary under Compensation Payments Summary Under Tax Topics- Income Tax Act- Section 9- Compensation Payments A lease inducement payment received by a firm in connection with its only business location generally will not be included in income. ...

.- "Confidentiality of Taxpayer Information"- "Section 241 of the Income Tax Act"-- summary under Paragraph 241(4)(b) Summary Under Tax Topics- Income Tax Act- Section 241- Subsection 241(4)- Paragraph 241(4)(b) The amendment would deal with the situation where information provided by a company in connection with a flow-through share issue reveals that a number of expenses allocated to investors do not meet statutory requirements. ...

February 1995 Manitoba Institute/Bar Round Table, Q. 1-- summary under Section 61.2 Summary Under Tax Topics- Income Tax Act- Section 61.2 A deduction may be claimed under s. 61.2 in the terminal return of the deceased, and no amount in connection with any claim under s. 61.2 will be added in computing the income of the estate or heirs of the deceased. ...

Convention, and it is a question of fact whether an arrangement is "in connection with a rental... agreement". ...