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Administrative Policy summary
Guidance on the Canada-U.S. Enhanced Tax Information Exchange Agreement 20 July 2020 -- summary under Subsection 265(2)
Must take into account AML information 7.24 In assessing whether reliance can be placed on a self-certification, a financial institution must consider other information that it has obtained concerning the account holder in connection with the account opening, including any documentation obtained for purposes of the AML/KYC Procedures and any information that an account holder voluntarily provides to it. ...
Administrative Policy summary
16 March 2009 Interpretation 110027 -- summary under Subsection 177(1.1)
The Nominee would further maintain all relevant corporate and accounting records in connection with such activities. ...
Administrative Policy summary
23 March 2017 CBA Commodity Taxes Roundtable, Q.4 -- summary under Subsection 240(1)
The lessor has no other relevant connection to Canada, e.g., agents, employees or facilities in Canada, soliciting of Canadian business, Canadian bank accounts or servicing obligations under the lease. ...
Administrative Policy summary
8 March 2018 CBA Commodity Tax Roundtable, Q.8 -- summary under Subsection 175(1)
Based on the information provided, the only connection between the firm and the candidate appears to be the seeking of a future employment opportunity. ...
Administrative Policy summary
28 February 2019 CBA Roundtable, Q.16 -- summary under Paragraph 141.1(3)(a)
28 February 2019 CBA Roundtable, Q.16-- summary under Paragraph 141.1(3)(a) Summary Under Tax Topics- Excise Tax Act- Section 141.1- Subsection 141.1(3)- Paragraph 141.1(3)(a) CRA accepts ONEnergy, including that “either” s. 141.1(3) or 141.01(2) can be satisfied ONEnergy … held that s. 141.1(3), which provides for an input tax credit where the property or service is acquired in connection with the acquisition, establishment, disposition or termination of a commercial activity, is more specific than s. 141.01(2), so that a person will not lose the entitlement to claim an ITC solely because that person is not making any taxable supplies at the time that such property or service is acquired. ...
Administrative Policy summary
27 February 2020 CBA Roundtable, Q.1 -- summary under Section 213
The aircraft is delivered or made available to Lessee under the novated lease when it is physically situated outside of Canada, following which the Lessee brings the aircraft into Canada in connection with its international transportation business. ...
Administrative Policy summary
Candice M. Turner, "Answers to Practical FATCA Questions for Canadian Financial Institutions", Tax Management International Journal, Vol. 43, No. 8, August 8, 2014, p. 484. -- summary under Paragraph A
However, the CRA Guidance provides that where a holder of a pre-existing individual account opens a new account with the same financial institution, there is no need to re-document the account so long as the due diligence requirements have been or are in the process of being carried out and, where a threshold has been applied in connection with the pre-existing account, the financial institution's computerized systems are able to link the new account to the pre-existing account. ...
Administrative Policy summary
31 October 2011 Interpretation Case No. 132880 -- summary under Financial Service
In such a case, there must be a direct and clear connection between the payment made to the Dealer (lump-sum or periodic) and the services provided in relation to the initial sale of the […] Shares to the Client. ...
Administrative Policy summary
Inter-Leasing, Inc. v. Ontario (Revenue), 2014 ONCA 575 -- summary under Clause 54(2)(b)
Ontario (Revenue), 2014 ONCA 575-- summary under Clause 54(2)(b) Summary Under Tax Topics- Other Legislation/Constitution- Ontario- Taxation Act 2007- Section 54- Subsection 54(2)- Clause 54(2)(b) situs of specialty debt was its place of holding In connection with a plan to minimize Alberta corporate tax, the Precision group of companies reorganized to implement a structure which, among other features, resulted in interest-bearing debts being owed to the taxpayer by a Yukon company in the form of deeds of specialty debt, which were physically transferred to the British Virgin Islands. ...
Administrative Policy summary
GST/HST Memorandum 14-5, Election to Deem Supplies to be Made for Nil Consideration, June 2023 -- summary under Qualifying Group
GST/HST Memorandum 14-5, Election to Deem Supplies to be Made for Nil Consideration, June 2023-- summary under Qualifying Group Summary Under Tax Topics- Excise Tax Act- Section 156- Subsection 156(1)- Qualifying Group Example 1 Where OpCo (a registrant substantially all of whose preoperty was acquired for use or supply exclusively in commercial activities) establishes NewCo, which performs activities in connection with the establishment of the commercial activity which it plans to carry out "and therefore becomes a registrant. ...