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This should enable you to reply to the Belleville District Office in connection with the above-noted taxpayer. ...

The administrative position of the Department with regard to the application of subsection 15(1) in connection with single purpose corporations continues to be as previously stated in response to questions at Revenue Canada Round Tables. ...

Following the last paragraph of Paragraph 68, as amended in paragraph 4 above, the following new paragraph is added: " In connection with securing the consent of Fco to the proposed transactions, prior to the transfers of property to the Siblings' Subs described in this Paragraph, the secured and unsecured, short and long-term indemnities in favour of Fco in connection with the disposition of Gco to Fco (see Paragraph 48 above) will be amended so that Aco and Father will indemnify Fco for all or a portion of any losses in respect of certain litigation involving Gco. Also, Fco will not consent to the novation of these secured and unsecured, short and long-term indemnities in favour of Fco in connection with the disposition of Gco to Fco, and, accordingly, there will not be a novation of such indemnities. ...

We understand that to the best of your knowledge, and that of XXXXXXXXXX and Investor, the issues involved in this advance ruling request have not been involved in an earlier return of XXXXXXXXXX or Investor or any person related thereto, have not been ruled upon by Revenue Canada in connection with XXXXXXXXXX or Investor or any person related thereto, have not been considered by a Tax Services Office or Taxation Centre in connection with a tax return already filed by XXXXXXXXXX or Investor or any person related thereto, are not under objection or appeal by XXXXXXXXXX or Investor or any person related thereto and are not before the courts. ... The Trust will also assume the obligation of Investor to reimburse XXXXXXXXXX for the costs incurred by it in connection with the acquisition of the XXXXXXXXXX Shares. ...

b) Will the costs include any debts assumed or incurred in connection with the acquisition of a real estate property whether through a direct title or limited partnership offering? ... In both the acquisition of a limited partnership interest and the direct title to a property, the “cost” may however be reduced by the aggregate of all amounts each of which is the amount of any “prescribed benefit” described in subparagraph b(ii) of the definition of “tax shelter” in subsection 237.1(l) of the Act and depending on the facts of a particular situation financing may be considered to be a “prescribed benefit” as defined in subsection 231(6) of the Income Tax Regulations (the “Regulations”), (see answer 2 below). b) In our opinion, the “cost” will include any debts assumed or incurred in connection with the acquisition of a real estate property if through direct title, however, where a limited partnership interest is acquired, the “cost” will include only those debts assumed or incurred in connection with the acquisition of the partnership interest itself and not any debts incurred by the partnership to acquire partnership property. ...

Grid connection for the Test Wind Turbines will be at the XXXXXXXXXX. Utility will build a new XXXXXXXXXX access line from the site to the highway to facilitate the connection. The feeder line and grid connection equipment will be owned by the Utility. ...

No deduction for expenses incurred in connection with research or professional development carried on by a faculty member in the ordinary course of employment duties. 962265 XXXXXXXXXX D. ... The types of deductions an employee is entitled to claim against employment income are limited to those provided under section 8 of the Act and does not include expenses incurred in connection with research or professional development carried on by a faculty member in the ordinary course of his or her employment duties. ... In addition, the faculty member would be eligible to claim that portion of the expenses incurred personally by the faculty member for professional development training that would qualify as tuition fees which were not reimbursed by XXXXXXXXXX An employee is not permitted to deduct the cost of attending a conference as this deduction is only permitted when a taxpayer is in receipt of business income and that the conference was held in connection with the business. ...

Oulton (613) 995-1787 Attention: XXXX Dear This is in reply to your letter dated April 15, 1981 wherein you requested an advance income tax ruling in connection with promoting the formation of an unspecified number of personal service corporations. ... Reference may be made to paragraphs 3 and 4 of Information Circular 70-6R dated December 18, 1978 in this connection. ... We are prepared to consider a ruling request in connection with the above-noted type of personal service corporations provided that there is a specific taxpayer and actual proposed contracts involved. ...

Item 21: We suggest deleting "copyrights" in this item since subsection 212(5) refers specifically only to the right in or to the use of motion picture film or videotape and other means of reproduction for use in connection with television. ...

In our view, provided that Serviceco is carrying on business in connection with its contract with Canco and that contract is in respect to the project, the employees of Serviceco will be eligible to claim the OETC provided that they otherwise satisfy all the conditions set out in section 122.3 of the Act. ...