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Ministerial Correspondence
28 September 2006 Ministerial Correspondence 2006-0204101M4 - Scholarship Exemption
Reasons: The draft legislation requires that the award be received in connection with an individual's enrolment in an educational program for which the individual may claim the education tax credit. ... The draft legislation indicates that the exemption will only apply if the award is received in connection with an individual's enrolment in an educational program for which the individual may claim the education tax credit. ...
Ministerial Correspondence
26 February 2010 Ministerial Correspondence 2010-0354981M4 - HRTC-Pellet Insert
A pellet insert requires an electrical connection [hard wiring] with most inserts requiring a conventional flue. ... Most pellet inserts require an electrical connection (hard-wired), as well as a conventional flue. ...
Ministerial Correspondence
8 November 1991 Ministerial Correspondence 911504 F - "Wage Protection Trusts"
You submit that, under the plan, contributions would be made by the particular employer to a trustee (custodian) in connection with benefits that may be received by a person on the loss of an office or employment of a taxpayer and, as such, you believe that the Trust would qualify as a "retirement compensation arrangement" ("RCA") as that term is defined in subsection 248(1) of the Income Tax Act (Canada) (the "Act"). ... Generally, an RCA is an arrangement under which contributions are made by an employer to a custodian to fund an amount to be paid to an employee in connection with benefits to be received on, after or in contemplation of (a) any substantial change in the services rendered by the employee, (b) the employee's retirement, or (c) the loss of the employee's office or employment. ... In our view, the payments to be made to the custodian by the employer are being made to indemnify the directors and officers of the employer in respect of their personal obligations under the proposed amendments to the Employment Standards Act of Ontario and are not made in connection with benefits that are to be or may be received or enjoyed by an employee of the employer on, after or in contemplation of any of the circumstances set out in (a), (b) or (c) above. ...
Ministerial Correspondence
10 August 1989 Ministerial Correspondence 58424 F - Private Health Services Plan
Szeszycki (613) 957-2103 August 10, 1989 24(1) Private Health Services Plan We are writing in connection with your letter of July 17, 1989, announcing the creation of a private health services plan by 24(1) 24(1) Although no formal notification to, or registration with, this Department is required in respect of the creation of private health services plans, we acknowledge receipt of your letter and confirm that no other reporting requirements exist. for DirectorSmall Business and General Division Specialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch ...
Ministerial Correspondence
10 June 2009 Ministerial Correspondence 2009-0320691M4 - In-kind RRSP withdrawals and TFSA contributions
In this regard, the income tax rules do not obligate financial institutions to accept in-kind transactions in connection with RRSPs and TFSAs, nor do the rules regulate the level of fees charged in connection with these registered accounts. ...
Ministerial Correspondence
19 January 2004 Ministerial Correspondence 2003-0053541M4 - Taxation of Indian EI training allowance
Reasons: It appears that the training in this case is done on reserve, which would create a sufficient connection to the reserve to make the amount tax-exempt. ... However, a sufficient connection to a reserve can be said to exist and the exemption becomes available when the training is actually taken on a reserve. ...
Ministerial Correspondence
18 January 1990 Ministerial Correspondence 74544 F - Employment Income
They import such meanings as "in relation to", "with reference to " or "in connection with". The phase "in respect of" is probably the widest of any expression intended to convey some connection between two related subject matters. ...
Ministerial Correspondence
7 August 1991 Ministerial Correspondence 911254 F - Overseas Employment Tax Credit (OETC)
From the information submitted by you, we understand the situation to be as follows: 1. 2. 3. 24(1) 4. 5. 6. 24(1) In order for an individual to be eligible to claim the OETC, the individual is required to perform all or substantially all (9O%) the duties of his employment in one or more countries outside Canada in connection with a contract under which the specified employer carried on business in such country or countries with respect to the qualified activities set out in subparagraphs 122.3(1)(b)(i) and (ii) of the Act other than for the performance of services under a prescribed international development assistance program of the Government of Canada. ...
Ministerial Correspondence
21 February 2005 Ministerial Correspondence 2004-0104611M4 - Indian tax - Guideline 4 and also fishing income
The employee's duties must be in connection with the employer's non-commercial activities carried on for the benefit of Indians who for the most part live on reserves. ... Finally, the individual's duties of the employment must be in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserves. ...
Ministerial Correspondence
16 June 2010 Ministerial Correspondence 2009-0310891M4 - Taxation of Postdoctoral Fellowships
The 2006 federal budget exempted post-secondary scholarship, fellowship, and bursary income from tax if the student receives the scholarship, fellowship, or bursary in connection with his or her enrolment in a program for which he or she can claim the education tax credit. ...