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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. ...

Accordingly, an individual who is not an employee, e.g. a self employed architect, is not eligible for the deduction form tax under this section. (2) The individual 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 any construction, installation, agricultural or engineering activity. ... The individual must have performed his duties of employment in the other country or countries in connection with the employer's contract. Thus, for example, individuals whose duties of employment are administrative office functions, e.g. bookkeeping, for their employer will be eligible if they are "in connection with" the performance by the employer of a contract of the kind described above. ...

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. ...

8 July 1981 Income Tax Severed Letter RCT 3-6201 F Unedited CRA Tags 85 Section 85Elections As discussed with you recently, enclosed herewith are the memorandum and related documentation received from the Saskatoon District Office in connection with the above-noted taxpayer. ... We await your comments in this matter and shall be pleased to provide any further assistance you may require in this connection. ...

We agree that the provisions of the said 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. ... In this context, it is your view that the exemption should continue to apply if "a motion picture is first filmed and then transferred to video tape for editing and other production and post-production work, with the final version remaining on video tape for use in connection with television". ...

We are now, after further consideration, of the opinion that the income of a foreign affiliate should only be accepted, for the purposes of subparagraph 95(2)(a)(i), as pertaining or being incident to the active business of a related foreign affiliate in very rare and unusual circumstances where the taxpayer substantiates that there is a direct connection between the income of the foreign affiliate and the active business of the related foreign affiliate. Based on our review of the information that has been provided to us, we do not feel that the taxpayer has substantiated that there is a direct connection between the interest income of XXX and the active businesses of any of its related foreign affiliates and on that basis we are in agreement with you that subparagraph 95(2)(a)(i) is not applicable and that the interest income is foreign accrual property income. ...

It is our understanding that XXX In order for an individual to be eligible to claim the OETC, in addition to meeting other conditions set out in subsection 122.3(1) of the Income Tax Act (the “Act”), the individual is required to perform all or substantially all the duties of his employment 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 paragraph 4(c) of Interpretation Bulletin IT-497R2. Based on the limited facts provided in your letters of October 25 and November 29, 1991 XXX In order for you to qualify for the OETC it would be necessary for XXX to demonstrate that they are carrying on business in Mexico in connection with a contract with respect to one or more of the qualified activities. ...

You further enquire as to whether an employee covered by an individual RPP could deduct any expenses paid by him in connection with establishing the RPP. ... In our opinion, an employee is not entitled to deduct expenses paid in connection with establishing an individual RPP since these expenses belong to the employer or the trustee of the RPP. ...

Our Comments Subparagraph 6(1)(b)(vii.1) of the Act provides that reasonable allowances for the use of a motor vehicle received by an employee (other than an employee employed in connection with the selling of property or the negotiating of contracts for the employer) from the employer for travelling in the performance of the duties of the office or employment are not taxable. However, subparagraph 6(1)(b)(x) of the Act provides that, for purposes of subparagraphs (v), (vi) and (vii.1), an allowance received in a taxation year by a taxpayer for the use of a motor vehicle in connection with or in the course of the taxpayer's office or employment is deemed not to be a reasonable allowance if the measurement of the use of the vehicle for the purpose of the allowance is not based solely on the number of kilometres for which the vehicle is used in connection with or in the course of the office or employment. ...

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”. In our view, mortgage interest paid by an employer in connection with an employee’s old residence should be included in the employee’s income under paragraph 6(1)(a) and subsection 6(23) of the Act because it is clearly in respect of the financing of a residence. ...