Search - connection

They import such meanings as "in relation to", "with references 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". the service fees paid by NRCO would be considered to be "in respect of" the SR & ED expenditures incurred by Canco. ...

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. ...

In connection with this "grandfathering provision", you have asked the following questions: 1. ... You point out that pursuant to subsection 215(6) of the Act the payor is held responsible for the tax which has not been deducted and withheld, and you wish to know whether in connection with Article XXX(5) of the new Convention the payor is entitled to rely on the recipient's representation of his fiscal year-end. ...

Robin Jackson Canadian Film & Videotape Certification Office Cultural Industries Directorate Department of Communications 16th Floor, Journal Tower South 365 Laurier Avenue, West Ottawa, Ontario K1A 0C8 Dear Robin: This is further to your letter of August 12, 1982 in connection with a proposal you have received from XXXX concerning XXXX While XXXX description concerning his proposals provide an illustrious description of his ideas and concepts, we are unable to draw definite conclusions as to whether or not any of the actual costs incurred will qualify as "computer software" within the meaning of paragraph (o) of class 12 of Schedule II to the Income Tax Regulations. ... In connection with the foregoing, we offer the following comments: 1. ...

A2-1 contributions made under the EBP after January 1, 1988 and all property that can reasonably be considered to derive from those contribution are deemed to be property held in connection with the statutory arrangement (RCA) and not in connection with the existing EBP. ...

It would seem likely that the great majority of persons who dispose of a life insurance policy in Canada would have or would at some point in a previous year have had an employment, business or property connection with Canada- that would bring them within subsection 2(3). Indeed, it would seem rather strange that a person who did not at some time have such a connection with Canada would acquire a life insurance policy in Canada to which subparagraph 115(l)(a)(vi) and subsections 116(5.1), (5.2) and (5.3) could apply in the first place. ...

It would appear that the employees described above are not "employed in connection with the selling of property or negotiating of contracts". ... " Provided that the number of cents per kilometre is reasonable in the circumstances (taking into account the employer's reimbursement of actual gas and oil expenses paid by employees in connection with their employer's business activities) it is our opinion that the income tax treatment of the mileage allowance, as suggested in 6 and 7 above, would appear to be appropriate. ...

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 24(1) matter on which we commented in our October 8, memorandum to your branch. ... The concept is reflected in other aspects of the Regulations dealing with insurance business policy reserves, particularly in connection with "reinsurance commission". ...

This interest expense was incurred in connection with the acquisition of a capital property, not in connection with a loan, the proceeds of which were directly used in the farm business, nor in the course of carrying on the farm business. ...

In essence, the taxpayers disposed of their principal residence (taking back a second mortgage), acquired a new principal residence and then were forced by circumstances to begin foreclosure proceeding in connection with the second mortgage. ... In this connection, there appears to be little, if any evidence to support the view that his original purpose on reacquisition was anything other than the use to which the property was put. (5) Where the property is sold for less than the cost determined under section 79, a loss results. ...