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Administrative Policy summary
IT-533 "Interest Deductibility and Related Issues" 31 October 2003 -- summary under Paragraph 20(1)(c)
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 purposes that would have qualified for interest deductibility had the capital been borrowed money (eligible purposes). ...
Administrative Policy summary
Guidance on the Canada-U.S. Enhanced Tax Information Exchange Agreement 20 July 2020 -- summary under Section 2
A financial institution must also confirm the reasonableness of the self-certification based on information it obtains in connection with the opening of the account, including any documentation obtained for the AML/KYC Procedures. 9.16 It is expected that financial institutions will have account opening processes that facilitates the collection of a self-certification at the time of the account opening. ...
Administrative Policy summary
Guidance on the Canada-U.S. Enhanced Tax Information Exchange Agreement 20 July 2020 -- summary under Subsection 265(8)
Dealer I and Dealer II have as account holders Investor A and Investor B, respectively, and both have Part XVIII responsibilities in connection with the financial accounts they maintain. ...
Administrative Policy summary
13 December 2018 Wheaton Precious Metals Press Release -- summary under Subsection 247(2)
In its December 13, 2013 Press Release, Wheaton announced the settlement of its appeal of these reassessments to the Tax Court: Wheaton Precious Metals Corp (“Wheaton” …) … has reached a settlement with the … CRA … which provides for a final resolution of Wheaton’s tax appeal in connection with the reassessment under transfer pricing rules of the 2006 to 2010 taxation years (the “Reassessments”) related to income generated by the Company’s wholly-owned foreign subsidiaries (“Wheaton International”) outside of Canada. ...
Administrative Policy summary
27 February 2020 CBA Roundtable, Q.1 -- summary under Clause 3(n)(i)(A)
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. ...