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With respect to the payments to U.S. residents referred to in 4 above, you ask us to confirm your view that such payments are not subject to Part XIII tax under subsection 212(5) of the Act because: (a) Although the payments are "on account or in lieu of payment of a motion picture film, or a film or video tape for use in connection with television", the film has not been used or reproduced in Canada. ...

In connection with acquiring ownership to computer software, in our view software is owned by the creator of the software or by a person who acquires the software in an outright sale. ...

We understand that to the best of your knowledge and that of XXX officials, none of the issues involved in this opinion request is being considered by a District Office or a Taxation Centre in connection with a tax return already filed, and none of the issues is under appeal or objection. ...

Co. in connection with any business carried on by it in Canada. 3. The loan is not repaid by the end of Year 2 with the result that subsection 15(2) and paragraph 214(3)(a) apply to deem the amount of the loan to be a dividend paid by Canco to U.K. ...

In connection with these comments, we have assumed that where the residence and related land can be regarded as having been used in a business, the residence and related land are typical of what would be provided to such an employee (i.e., not luxury accommodation), and that more than 50% of the residence is used directly in the business in question or as accommodation for theemployee/manager or his dependents. ...

X attends directors' meetings of Canco but is also frequently consulted by senior management of Canco in connection with its business affairs. ...

In any event, it seems to be the first date that the public was made aware of any formal. interpretive guidelines for "traders or dealers", since we are unaware of any other formal instructions in connection with this issue. ...

Oulton (613) 995-1787 September 16, 1983 Dear Sirs: This is in reply to your letter dated July 21, 1983 in connection. with the definition of a specified investment business in paragraph. 125(6)(h) of the Income Tax Act (the Act) as it relates to the test of the number of employees for a corporation which is a member of a corporate partnership. ...

In connection with a registered pension plan which restricts annual contributions by members to the lesser of $3,500 and 20% of the member's earned income for the year, you have asked whether or not benefits included in the computation of an employee's taxable income in respect of income for purposes of computing the employee's maximum pension contribution. ...

As we also indicated in our telephone conversation, the proposed legislation reflected in Bill C-54 contains a provision with respect to income from services performed abroad which reads as follows: "Where any individual is resident in Canada in a taxation year and, throughout a period of more than six consecutive months that commenced in the year or a previous year (in this subsection referred to as the "qualifying period"), (a) was employed by a person who was a specified employer, (b) performed all or substantially all the duties of his employment in one or more countries other than Canada (i) in connection with a contract under which the specified employer carried on business in such country or countries with respect to (A) the exploration for, or exploitation of, petroleum, natural gas, minerals or other similar resources, (B) a construction, installation, agricultural or engineering activity, or (C) any prescribed activity, or (ii) for the purpose of obtaining a contract for the specified employer to undertake any of the activities referred to in clause (i)(A), (B) or (C). there may be deducted in computing his income for the year from that employment an amount equal to the lesser of (c) that portion of $50,000 that the number of days in that portion of the qualifying period that is in the year is of 365, and (d) 50% of the portion of the amount that would, but for this subsection, be his income for the year from that employment that is reasonably attributable to those duties performed (i) if section 114 is applicable, during the period or periods in the year referred to in paragraph 114(a) that are within the qualifying period, or (ii) if section 114 is not applicable, within the qualifying period. ...