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Administrative Policy summary

1993 A.P.F.F. Round Table, Q.15 -- summary under Payment & Receipt

There also is no repayment of the debt if it is assumed by another taxpayer in connection with the transfer to that other taxpayer of the assets for which the loan was contracted. ...
Administrative Policy summary

1993 A.P.F.F. Round Table, Q.15 -- summary under Paragraph 20(1)(hh)

There also is no repayment of the debt if it is assumed by another taxpayer in connection with the transfer to that other taxpayer of the assets for which the loan was contracted. ...
Administrative Policy summary

May 1998 Conference for Advanced Life Underwriting Round Table, Q. 3, No. 9807000 -- summary under Retirement Compensation Arrangement

May 1998 Conference for Advanced Life Underwriting Round Table, Q. 3, No. 9807000-- summary under Retirement Compensation Arrangement Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Retirement Compensation Arrangement Where amounts paid to an RCA are returned in some manner to the employer, Revenue Canada "may question whether or not an RCA exists, as contributions under the arrangement may not be made in connection with benefits that are to be received by the taxpayer". ...
Administrative Policy summary

89 C.R. - Q.18 -- summary under Term Preferred Share

.- Q.18-- summary under Term Preferred Share Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Term Preferred Share In determining whether an issuer of a share is controlled by a specified financial institution either alone or together with any other specified financial institution for purposes of paragraph (b), one of the factors to be considered is whether such specified financial institutions have sufficient common connections or business interests. ...
Administrative Policy summary

10 June 1993 Memorandum (Tax Window, No. 32, p. 4, ¶2594) -- summary under Retiring Allowance

10 June 1993 Memorandum (Tax Window, No. 32, p. 4, ¶2594)-- summary under Retiring Allowance Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance Where in an out-of-court settlement of a suit brought in connection with the termination of employment, an amount is allocated as damages for violation of human rights, it must be established that human rights issues were involved and that the payment was reasonable compared to awards ordered by actual tribunals, in order for such amount not to be considered a retiring allowance. ...
Administrative Policy summary

June 2012 Draft GST/HST Technical Information Bulletin B-103, "Harmonized Sales Tax - place of supply rules for determining whether a supply is made in a province" -- summary under Paragraph 8(b)

June 2012 Draft GST/HST Technical Information Bulletin B-103, "Harmonized Sales Tax- place of supply rules for determining whether a supply is made in a province"-- summary under Paragraph 8(b) Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 8- Paragraph 8(b) Ontario office referenced only in website more closely connected than home billing address Includes Example 49 (lawyer operates a law firm in Ontario designates her Quebec home as the billing address but also provides the Ontario office address respecting an online law website with no area restrictions- Ontario address has the closer connection). ...
Administrative Policy summary

P-239 "Meaning of the Term 'Arranging For' as Provided in the Definition of 'Financial Service'" 30 January 2002. 31 March 2000 HQ Letter 25522 -- summary under Financial Service

P-239 "Meaning of the Term 'Arranging For' as Provided in the Definition of 'Financial Service'" 30 January 2002. 31 March 2000 HQ Letter 25522-- summary under Financial Service Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Financial Service A commitment fee payable in connection with a merger transaction entailing share and note consideration represented consideration for a financial supply. ...
Administrative Policy summary

4 April 2011 Headquarter Letter Case No. 87088 -- summary under Section 7

4 April 2011 Headquarter Letter Case No. 87088-- summary under Section 7 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part I- Section 7 a lease of land located at a lake resort site became exempt under s. 7(a)(i) when the individual's husband retired and began to use a park model trailer, which was installed in a permanent manner at the site (including connection to hydro, gas, water and septic facilities), as his place of residence from May to October of each year, with the individual spending her weekends and summer periods there. ...
Administrative Policy summary

4 April 2011 Headquarter Letter Case No. 87088 -- summary under Residential Unit

4 April 2011 Headquarter Letter Case No. 87088-- summary under Residential Unit Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Residential Unit a lease of land located at a lake resort site became exempt under s. 7(a)(i) when the individual's husband retired and began to use a park model trailer, which was installed in a permanent manner at the site (including connection to hydro, gas, water and septic facilities), as his place of residence from May to October of each year, with the individual spending her weekends and summer periods there. ...
Administrative Policy summary

GST/HST Memorandum 28-3 [28.3] Passenger Transportation Services July 2019 -- summary under ; Stopover

However, when the stop is longer than 24 hours and is for connection purposes only, the supplier or agent must provide supporting evidence that the interruption is not a stopover. ...

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