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In connection with a reimbursement of Maintenance Costs incurred by a POH with respect to a blind trust, you have indicated that while recommendations are only made on the basis of the limits set out above, the calculations of reimbursements are based on the market value of all assets entrusted. ...

We would like to point out that for the employee to qualify for the OETC in situation 2 described in your memorandum, throughout the time he spent in Canada, the employee must still have been employed by a specified employer in connection with a contract referred to in subparagraph 122.3(1)(b)(i) of the Act or for the purpose of obtaining such a contract on behalf of the specified employer. ...

In this connection, the federal Copyright Act in section 2 provides that a book "includes every volume, part or division of a volume, pamphlet, sheet of letterpress, sheet of music, map chart or plan separately published". ...

The court also held at page 1142 that: “Having regard to the business carried on by a non-resident insurer, that is, the business of insurance, the definition of “Canadian reserve liabilities” is broad enough to include the liabilities and reserves reported to the relevant authority under the relevant provisions of the Insurance Act which have a connection, directly or indirectly, with the insurer's insurance policies in Canada.” ...

The wording in the brackets in paragraph 3 Article XII of the Convention may create some ambiguity since it was not clear whether the words "for use in connection with television" applied only to the last term "other means of reproduction" or whether it applied to the other antecedents in the brackets. ...

22 December 1989 Income Tax Severed Letter 5-8642B Unedited CRA Tags 85(1) Dear Sirs: This is in reply to your letter of August 24, 1989 in which you requested our opinion regarding issues that have arisen in connection with a transaction which involves a non-arm's length inter-corporate transfer of property, subject to a subsection 85(1) election, followed by an arm's length sale of the transferred property by the corporate transferee which has available non-capital losses. ...

Dear Sirs: Re: Non-resident Withholding Tax This is in reply to your letter of February 25, 1986 requesting a technical interpretation in connection with a hypothetical fact situation therein. ...

We are unable to see the connection with Part XIll requirements on similar amounts paid to non-residents. ...

Subparagraph 212(1)(d)(iii) A payment for the type of services in question will not be subject to Part XIII tax under subparagraph 212(1)(d)(iii) of the Act provided the payment is (a) not dependent in whole or in part upon (i) the use to be made thereof or the benefit to be derived therefrom, (ii) production or sales of goods or services, or (iii) profits, or (b) made for services performed in connection with the sale of property or the negotiation of contracts. ...

In this connection, the federal Copyright Act in section 2 provides that a book "includes every volume, part or division of a volume, pamphlet, sheet of letterpress, sheet of music, map chart or plan separately published". ...