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The Department's position with respect to expenditures incurred, directly or indirectly in connection with a winding-up is set out generally in paragraph 31 of Interpretation Bulletin IT-488R. ...

This is in reply to your memorandum of March 23, 1981 in connection with the enquiries made by XXXX concerning the income tax implications in the following situation: "A taxpayer entered into a life annuity contract in 1979 providing for a single premium payment. ...

Fioravanti (613)957-8962 July 19, 1988 Dear Sirs: This is in reply to your letter of June 23 requesting our interpretation of the definition of a retirement compensation arrangement ("RCA") as defined by subsection 248(1) of the Income Tax Act (the "Act"), in connection with an accounting accrual to be made in respect of supplementary pension benefits. ...

Consequently, we are not prepared to respond definitively to questions raised in connection with a portion of such an arrangement without examining the entire settlement document. ...

RESPONSE As stated in paragraph 6 of IT99R4, it is the Department's practice to allow a taxpayer to deduct amounts expended in connection with legal and accounting fees incurred for advice and assistance in making representations after having been informed that the taxpayer's income or tax for a taxation year is to be revised, whether or not a formal notice of objection or appeal is subsequently filed. ...

Concerning a fixed monthly or annual car allowance, it is our view that such an allowance would be taxable to the recipients by virtue of subparagraph 6(1)(b)(x) of the Act as the allowance would not appear to be based solely on the number of kilometres for which the motor vehicle is used in connection with or in the course of their office or employment. ...

McColm Chief, Corporate Reorganization 957-2068 and Distribution Tax Policy and Legislation branch BY HAND Department of Finance I-3462 140 O'Connor Street L'Esplanade Laurier 17th Floor, East Tower Ottawa, Ontario K1A OG5 Dear Wally: Re: Portfolio Investments Section 94.1 of the Income Tax Act Attached for your information is a submission received from our Specialty Rulings Directorate in connection with an request for an advance income tax ruling concerning section 94.1 of the Income Tax Act. ...

The reference in paragraph (2) of Article 19 to "services rendered in connection with a business carried on by a Contracting State... ...

5 March 1981 Income Tax Severed Letter RCT-0281 F Unedited CRA Tags none This is in reply to your memorandum of September 19, 1980 in connection with the above-noted taxpayer. ...

You have indicated that the farmer is likely involved in purchases of semen for use in his own herd and may sell semen produced by his own bulls, but is not involved in purchases and sales of rights to future semen sales of the type referred to above other than in connection with transactions involving the bulls themselves. ...