Search - connection

We apologize for the delay in responding to you, which arose because we considered it necessary to undertake consultations with the Department of Finance in connection with subparagraph 7(b) of Article 13 of the Convention. ...

One of these exclusions, contained in paragraph (b) of the definition, is that a program taken in connection with, or as part of the duties of an office or employment is excluded if the student receives income from that office or employment during the period during which the program is taken. 21(1)(b) Director General Financial Industries Division Rulings Directorate ...

Postal Services employees would be "in respect of services rendered in connection with a trade or business carried on by a Contrasting State" and no longer exempt from tax in Canada as government service. ...

Day (613) 957-2136 DEC 28 1988 XXXX We are writing in reply to your letter of November 20, 1988, wherein you requested our views as to whether moving expenses, incurred in connection with your move from XXXX could be deducted in computing your income for income tax purposes. ...

Leger 900089 Deductibility of Medical Expenses in respect of 19(1) We are enclosing for your information a copy of our correspondence with 19(1) who has asked us to provide a ruling or opinion with respect to the deductibility of amounts paid in connection with 24(1) As you will note from our response to 19(1) we have indicated that the application of paragraph 118.2(2)(e) of the Act hinges on whether the school, qualifies as one that specially provides the facilities, equipment, or personnel required for the care and training of individuals suffering from the condition described in his submission. ...

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. ...

I have one follow up question which I would appreciate receiving your reply to in connection with your comments on page 2 of the said letter dealing with the source of the income where one U.S. resident concludes an agreement of sale in the United States with another non resident in respect of a "life insurance policy in Canada". ...

It is our position that, under subparagraphs 115(1)(a)(i) and 115(2)(e)(1) of the Act, remuneration paid by a Canadian employer to a non-resident that is attributable to employment performed outside Canada would generally not to included in computing taxable income earned in Canada, for the purpose of the election under section 217 of the Act, 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. ...

Thornley (613) 957-2101 NOV 23 1988 Dear Sirs: Re: Broadcasting License This is in reply to your letter of October 19, 1988 requesting our confirmation of the classification of a broadcasting licence to be acquired in connection with a transaction by which a corporation will be selling to another corporation, the assets of a ratio station. ...

With respect to your request for an opinion regarding of legal and accounting fees already made, we make reference to Interpretation Bulletin IT-99R3- Legal and Accounting Fees, which sets out T paragraph 19 the Department's position with respect to fees incurred in connection with a prosecution under section 239 of the Act. ...