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Specifically, you requested our views whether the loan described above would be considered, for purposes of paragraph 149(4)(d) of the Act, a debt incurred in connection with the purchase and sale of investments. ... In any specific case the determination as to whether debts are incurred "in connection with" the purchase and sale of investments is a question of fact to be determined on the basis of all the details in that case. In our view the words "in connection with" contemplate a direct relationship between the incurring of the debt and the purchase and sale of investments. ...

7 June 1991 Income Tax Severed Letter- Overseas Employment Tax Credit Unedited CRA Tags 122.3 Dear Sirs: This is in reply to your letter dated March 7, 1991 whereby you requested our opinion as to whether an employee would be considered to perform the duties of his employment in XXX in connection with a contract under which the employer carries on business in XXX for the purposes of qualifying for the overseas employment tax credit provided under section 122.3 of the Income Tax Act (the "Act"). ... XXX Our Comments An individual (employee) must have performed all or substantially all the duties of his employment in one or more countries other than Canada in connection with a contract under which the specified employer carried on business in such other country or countries with respect to the exploration for or exploitation of petroleum, natural gas, minerals or other similar resources. ... In order for us to reach a conclusive opinion on such a transaction, we would have to review the contract itself and its connection, if any, with Canco's acquisition of the XXX. ...

They import such meanings `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. ... There is no requirement that the revenue guarantee have any connection with either the production of the video or the ownership of the video. ...

Secondly, the recent amendments to Subsection 6(2) of the Act, which defines the "reasonable standby charge", now restricts the entitlement to a reduced standby charge to those employees whose use of the automobile, as measured in kilometres driven, in connection with the duties of his employment is at least 90%. In this regard, the wording of subsection 6(6) of the Act does not support your assumption that the kilometres driven between the principal residence and the specia1 work site would be considered as kilometres driven in connection with the duties of employment. Consequently, in each of the examples provided by you the distance travelled in connection with the duties of employment would be limited to 10,000 kilometres, well under the 90% of total kilometres needed to become entitled to a reduced standby charge. ...

All contributions made under the EBP after the establishment of the Statutory Arrangement and all property that can reasonably be considered to derive from those contributions are deemed to be property held in connection with the Statutory Arrangement and not in connection with the Existing Arrangement. Therefore, income from the property (including a deferred annuity) in connection with the Existing Arrangement will be subject to the provisions of the Act dealing with an EBP. ... On the other hand, income from the property (including a deferred annuity) in connection with the Statutory Arrangement will be subject to the new RCA provisions of the Act. ...

You advised during a subsequent telephone conversation XXX Dodd) that the employee benefit plan texts were merely supplied for purposes of general information in connection with certain registration matters. You confirmed that as such, no comment from this office was required in connection with these plans and accordingly, we are closing our file. ...

We have reviewed the issue raised in your memo and are of the opinion that the sale of goodwill that occurred in connection with the sale and cessation of the taxpayer's entire business would not produce income that is considered to be active business income, although the matter is not free from doubt. ... Such an amount arising in connection with the sale of the business is thought to fall outside this phrase and thus is not considered to be ancillary to the activities involved in carrying on the business. ... Nor do we think that it is income "from a... business" (this phrase was discussed above in connection with subsection 14(1)). ...

This reduced standby charge is applicable provided the employee is required by the employer to use the automobile in connection with, or in the course of, the office or employment, and "all or substantially all" of the distance travelled by the automobile during the days in the year that it is available to the employee is in connection with, or in the course of, the office or employment. The Department considers the phrase "all or substantially all" to mean at least 90% of the distance travelled being in connection with, or in the course of, the office or employment. ...

The technical issue arises in connection with the attempted filing by the taxpayer of a waiver in respect of his 1985 income tax return. ... In connection with the technical issue, we have been advised by the Department of Finance, Tax Policy and Legislation Branch, that the reference point in paragraph 152(4)(a) from which the waiver filing deadline is determined, is intended to be the date of issuance of either the original assessment or the original notification. ... In connection with the question of whether we would accept a late-filed election under subsection 110.4(2), we consulted with Assessing and Enquiries Directorate who advised us that even if the waiver in question was valid and 19(1) 1985 return was open, it is not the Department's policy to accept requests to file a late-filed election pursuant to subsection 110.4(2) of the Act. ...

This position is based on the assumption that the signal is direct from the event being shown and is not based on some intermediate source such as a video tape; for example, the latter may occur when there is a delay of several seconds before being broadcast to viewers. 2) The Department considers pre-scripted programming to be subject to copyright in Canada and thus payments in respect thereof are exempt from withholding tax where they are in respect of the production or reproduction of any literary, dramatic, musical or artistic work and are not in respect of motion picture film or a film or videotape for use in connection with television broadcasting. Such royalty payments are subject to withholding tax however when they are in respect of motion picture film or a fil-m or videotape for use in connection with television broadcasting. 3. Instant replay of non-scripted or pre-scripted live programming is considered to be sourced in a videotape which is for use in connection with television broadcasting and is thus subject to withholding tax pursuant to 212(5) of the Act and Article XIII of the Treaty. 4. ...