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Our comments Guideline 4 will apply to exempt all the employment income of an Indian, regardless of where their employment duties are performed, where a) the employer is resident on the reserve; b) the employer is an Indian band, tribal council or an organization controlled by one or more such bands or tribal councils, if the organization is dedicated exclusively to the social, cultural, educational or economic development of Indians who for the most part live on reserves; and c) the duties of the employment are in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserves. ... The last element in Guideline 4 is that the duties of employment must be in connection with the employer's non- commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserves. ...

., [1949] S.C.R. 287 [49 DTC 514], where it was held that commission payments were not allowable as deductible expenses since they were incurred in connection with the financing of the business and were not related to the income earning process. ... Broadhurst's summary in the 1989 Conference Report ("Income Tax Treatment of Foreign Exchange Forward Contracts, Swaps and Other Hedging Transactions" p. 26:13): The case law in Canada has consistently regarded payments made in connection with the financing of a company's operation as being on capital account unless the taxpayer is engaged in a money-lending business. ...

We enclose herewith a copy of Form T106 including the Instructions in connection therewith that are printed on the reverse side of the Form which may be of assistance to you should you have any further questions in connection with this matter. ...

While the language of this Treaty is not as supportive of the approach (in favour of the taxpayer) adopted by the Courts in connection with the 1942 US Treaty, in Smith the Court held that the old UK Treaty should be interpreted in essentially the same manner as the Courts subsequently held the 1942 US Treaty should be interpreted. ... Also, on the subsequent period of temporary residence in Canada, the teacher must be coming from Ireland or Denmark and presumably must have some connection to that Country (beyond having simply come from there in transit from somewhere else) in order to have the benefit of the Treaty. (3) (a) Paragraph 1(b) of IT-68R2 states that: "a period not exceeding two years means one period that does not exceed 24 months". ...

Assuming that such a reserve would be established in connection with a self insured benefit plan, the amount of an employer's contribution to a health and welfare trust in respect of such a plan must be based on sound actuarial principles (The establishment of an arbitrary reserve that is contingent is not acceptable.). ... In connection with this comment, we also note that a shareholder or officer would not be considered an employee representative. ...

However, in determining whether a property is a tax shelter for the purposes of section 237.1 of the Act, the calculation of deductible losses and other deductible amounts is to be made on a prospective basis based upon statements or representations made or proposed to be made in connection with that property. If it may reasonably be considered, having regard to the statements and representations made or proposed to be made in connection with the property, that a purchaser will be entitled to deduct losses or other amounts in excess of the cost of the interest in the property to the purchaser at the end of any particular year after the deduction of prescribed benefits, then the property is a tax shelter. ...

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, connexion, combination... ...

(a) another plan or arrangement (referred to as the “statutory arrangement”) is deemed to be established on the day that is the earlier of January 1, 1988, and the date after October 8, 1986 on which the terms of the existing arrangement have been materially altered; (b) the statutory arrangement is deemed to be a separate arrangement independent of the existing arrangement; (c) the existing arrangement is deemed not to be a retirement compensation arrangement; and (d) all contributions made under the existing arrangement 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. ...

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". ...

Corporate Reorganizations Section Specialty Corporations Division Corporate Rulings Directorate QUESTION: What are the Department's views of the case of Holmes v The Queen, 74 DTC 6143, in connection with its assessing practices of "management companies" which apparently ignore that case. ... In general, the Department will not challenge the reasonableness of salaries and bonuses paid to the principal shareholders/ managers of a corporation when (i) the general practice of the corporation is to distribute the profits of the company to its shareholders/managers in the form of bonuses or additional salaries; or (ii) the company has adopted a policy of declaring bonuses to the shareholders to remunerate them for the profits the company has earned which are in fact attributable to the special know how, connections or entrepreneurial skills of the shareholders. ...