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Baines FILE DOSSIER 900601 SUBJECT: OBJET: xxxxx We are writing in reply to your round trip memorandum dated April 27, 1990 in which you request our views on the latest arguments raised by the taxpayer in connection with the above noted appeal. xxxxx on which we commented in our October 8, xxxxx memorandum to your Branch. ... The concept is relfected in other aspects of the Regulations dealing with insurance business policy reserves, particularly in connection with "reinsurance commission". ...

Subparagraph 5907(1)(d)(vi.1) of the Regulations provides for an adjustment to the exempt surplus account of a foreign affiliate in respect of an ACT credit received by it in connection with a dividend from another affiliate that is added to the exempt surplus of the recipient pursuant to subparagraph 5907(1)(d)(vi) of the Regulations and subsection 5907(7.1) of the Regulations provides for adjustments to the surplus accounts of a U.K. foreign affiliate in respect of an ACT credit received by a Canadian company in connection with a dividend paid to the Canadian company by the U.K. foreign affiliate. ...

They are not reimbursed, in whole or in part, by the corporation for the expenses they might incur with respect to the operation of their vehicles in connection with their corporate employment. ... In addition to the above, the corporation pays both husband and wife a “per kilometre” allowance for the use of their respective vehicles in connection with their employment duties with the corporation. ...

They import such meanings as “in relation to”, “with reference to” or “in connection with”. The phrase “in respect of” is probably the widest of any expression intended to convey some connection between two related subject matters”. 2. ...

In connection with this question, you have provided sales literature from a U.S. software supplier. ... It is our position that the following two conditions must be met in order for payments for any services, including a hot line service, provided in connection with the use of computer software not to be considered part of the software licence fee which is subject to Part XIII tax: 1. ...

A similar technical interpretation is put forth in connection with the existing paragraph 8(1)(h) where a claim for travelling expenses other than automobile expenses could be denied if the taxpayer is in receipt of a non-taxable automobile allowance. ... Such an administrative policy is in place in connection with expense claims to which paragraph 8(1)(h) presently applies. ...

Two of the bonds are issued in satisfaction of a pre-existing intercompany debt. withholding tax payable under Part XIII of the Act in connection with the repayment of the pre-existing indebtedness was deducted and remitted in accordance with the provisions of the Act. ... You wish to know whether withholding tax is payable by the U.S. lenders under Part XIII of the Act in connection with the interest paid on the bonds. ...

Two of the bonds are issued in satisfaction of a pre-existing intercompany debt. withholding tax payable under Part XIII of the Act in connection with the repayment of the pre-existing indebtedness was deducted and remitted in accordance with the provisions of the Act. ... You wish to know whether withholding tax is payable by the U.S. lenders under Part XIII of the Act in connection with the interest paid on the bonds. ...

In addition, you have requested our views with respect of withholding in two other areas. 1) Videotaped Television Programs Physically Shipped to Canada Subsection 212(5) of the Income Tax Act (the "Act") requires that a non-resident pay an income tax of 25% on every amount that a person resident in Canada pays for the use of such videotape that is for use in connection with television in Canada. ... Treaty. 5) Subsection 212(5) of the Act applies to an amount paid to a non-resident for the right to use videotapes in connection with television in Canada. ...

In connection with this question, you have provided sales literature from a U.S. software supplier. ... It is our position that the following two conditions must be met in order for payments for any services, including a hot line service, provided in connection with the use of computer software not to be considered part of the software licence fee which is subject to Part XIII tax: 1. ...