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Miscellaneous severed letter

12 January 1990 Income Tax Severed Letter AC59199 - Advance Income Tax Ruling Request November 29, 1990

A statement as to whether any of the issues involved in the ruling request are, to the best of your client'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 ore under objection or appeal. 3. ...
Miscellaneous severed letter

18 January 1991 Income Tax Severed Letter

In connection with your concern, you have indicated that since interest earned on overpayment of tax must be included in income, interest charged on income taxes should be deductible. ...
Miscellaneous severed letter

11 March 1993 Income Tax Severed Letter 9301955 - Education Tax Credit for CGA Students not Working in Acting

The criteria required to be met in order for the program to qualify as a "qualifying educational program" are set out in subsection 118.6(1) of the Act but excludes any such program if (b) "the program is taken by the student (i) during a period in respect of which he receives income from an office or employment, and (ii) in connection with, or as part of the duties of, that office or employment. ... In our view the expression "in connection with" has a broader meaning than the adjoining phrase contained in (ii) above, "as part of the duties of" and would include any students who are employed in an accounting related field. ...
Miscellaneous severed letter

7 July 1993 Income Tax Severed Letter 931140A F - Meal Allowance

They import such meanings as "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.' The word "for" in paragraph 67.1(2)(e) can not be interpreted to mean "with respect to" or "in respect of". ...
Miscellaneous severed letter

10 January 1990 Income Tax Severed Letter AC58903 - Moving Expenses

Connection fees for the following only where they existed at the old residence: telephone, water, heating, hydro, T.V. antennas, barbecues, water softeners, water heaters, air conditioners, automatic garage door openers, space heater, installation of carpets, curtains, drapes and tracks. 2. ... Long distance telephone charges in connection with the disposition of the former residence or the acquisition of the new residence. 5. ...
Miscellaneous severed letter

10 August 1989 Income Tax Severed Letter 5-8165 - Equity-building lease program

Since you have not requested an advance income tax ruling, our comments are of a very general nature and should not be taken as exhaustive of all the possible income tax consequences that can arise in connection with the proposal. ... Rental Recapture Rule If a farmer exercises his purchase option, a special rule set out in subsection 13(5.2) of the Act applies to rentals previously deducted by the farmer (or by a non-arm's length person) in connection with the property. ...
Miscellaneous severed letter

2 September 1992 Income Tax Severed Letter 9210595 - Education Tax Credit

The criteria required to be met in order for the program to qualify as a "qualifying educational program" are set out in subsection 118.6(1) of the Act but excludes "any such program if the program is taken by the student (i) during a period in respect of which he receives income from an office or employment, and (ii) in connection with, or as part of the duties of, that office or employment. ... Furthermore, the requirement for enrolment as a full-time student at a designated educational institution is a separate test over and above the requirement respecting a "qualifying educational program", a test similar to that described in paragraph 12 of IT-515 in connection with "full-time attendance". ...
Miscellaneous severed letter

23 November 1992 Income Tax Severed Letter 9234525 - Class 12(1)(s) - Point-of-Sale Equipment

The word "conjunction" is defined in The Oxford English Dictionary to mean "joining together, marriage union, connection of ideas,...the action of conjoining; the fact or condition of being conjoined; union, connection, Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information combination... ...
Miscellaneous severed letter

21 August 1992 Income Tax Severed Letter 9221826 - Maintenance Payments

Your memorandum uses the term "intangible property" in connection with the payment of an expense. ... Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information The first exception, as referred to in 2. a) above, could include the SCDE itself, with the expenditures being the mortgage payments or items purchased in connection with the maintenance of the property, such as hardware supplies. ...
Miscellaneous severed letter

7 July 1996 Income Tax Severed Letter 9624563 - Related group loss utilization scheme

We also acknowledge your letter of XXXXXXXXXX and our telephone conversations in connection herewith. We understand that to the best of your knowledge and that of the taxpayers involved none of the issues involved in the requested rulings is being considered by a district office or a taxation centre in connection with a tax return already filed, or is under objection or appeal. ...

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