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Miscellaneous severed letter

7 July 1990 Income Tax Severed Letter - Requirements for an advance income tax ruling

A ruling request must also contain a statement as to whether or not any of the issues involved are to the best of the taxpayer's knowledge being considered by a District Office and/or Taxation Centre in connection with a tax return already filed, or if any of the issues are under objection. ...
Miscellaneous severed letter

19 June 1989 Income Tax Severed Letter 5-7743 - [Paragraph 8(1)(f) of the Income Tax Act]

Where the taxpayer incurs expenses in connection with costs of leasing a computer rather than purchasing the computer. ...
Miscellaneous severed letter

7 August 1991 Income Tax Severed Letter - Overseas Employment Tax Credit

XXX In order for an individual to be eligible to claim the OETC, the individual is required to perform all or substantially all (90%) 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. ...
Miscellaneous severed letter

7 August 1991 Income Tax Severed Letter - Licences or Permits for Setting Up a Corporation

You may also wish to contact the jurisdiction under which you are proposing to incorporate your business (Federal or Provincial) to determine any requirements which they may have in connection with your business. ...
Miscellaneous severed letter

31 July 1985 Income Tax Severed Letter A-1627

We agree that the provisions of Article XIIIC exempt from tax, otherwise imposed by subsection 212(5) of the Income Tax Act, payments made for the right in or to the use of a videotape for use in connection with television broadcasting. ...
Miscellaneous severed letter

7 November 1990 Income Tax Severed Letter 146A

provided that such remuneration is subject to income tax imposed by a country other than Canada, or is paid in connection with the selling of property, negotiating of contracts or rendering of services for his employer in the ordinary course of a business carried on by his employer. ...
Miscellaneous severed letter

20 June 1980 Income Tax Severed Letter RCT-0563B

In connection with the five year repayment requirement in subparagraph 212(1)(b)(vii), it is our position that foreign currency fluctuations of the Canada dollar as against the U.S. dollar will not be taken into account in determining as at a particular date whether the Canadian borrower is under any circumstances obliged to pay are than 25% of the principal amount of the loan referred to above within five years of the date of issue. ...
Miscellaneous severed letter

19 September 1989 Income Tax Severed Letter RCT-0592A

In this connection you asked that we consider certain measures which would provide relief for these taxpayers. ...
Miscellaneous severed letter

5 July 1984 Income Tax Severed Letter 9A-0043 F

Convention will operate to exempt from tax awards of damages or payments pursuant to out of court settlements made in connection with the wrongful misappropriation of copyrights, since both provisions refer to payments made pursuant to the terms of consensual agreements. ...
Miscellaneous severed letter

16 March 1987 Income Tax Severed Letter 95-2808 F

In this connection see subparagraph 1(b) of Interpretation Bulletin IT-361R. ...

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