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However, it should be noted that paragraph 6(1)(b)(x) of the Act deems an allowance to be in excess of a reasonable amount where the measurement of the use of the vehicle for the purpose of the allowance is not solely based on the number of kilometres for which the motor vehicle is used in connection with the office or employment. ...

However, paragraph 6 of Article XI of the Convention states that"...the person paying the interest, whether he is a resident of a Contracting State or not, has in a State other than that of which he is a resident a permanent establishment...in connection with which the indebtness on which the interest is paid was incurred, and such interest shall be deemed to arise in the State in which the permanent establishment..is situated and not in the State of which the payer is resident". ...

In this connection please see paragraph 2 of Article XXII of the Treaty. ...

Paragraph 255(b) further provides that "Canada" includes the seas and airspace above the aforementioned submarine areas in respect of any activities carried on in connection with the exploration or exploitation of such minerals, petroleum, natural gas or hydrocarbons (See paragraph 4 of interpretation Bulletin IT-494). ...

As you know, the department has not accepted these arguments and our view of non-deductibility was recently conveyed to you (May 28, 1990) in connection with a submission on the subject by 24(1) In the present case, it would appear that the D.O. proposal extends beyond our general position on the buring cost issue in that it would disallow not only amounts in respect of premiums which might become payable in the future but also amounts which are in fact paid (or payable) on a current basis. ...

Thornley (613) 957-2130 June 12, 1986 Dear Sirs: Re: Exemption Test Policy This is in reply to your letter of April 4, 1986 concerning the calculation of the exemption test policy in connection with a "universal life policy" which in your words "must be qualified as 'exempted' during the active life of the policy". ...

Your main concern appears to be whether either a cash reimbursement to the XXXX of some or all all of its expenses incurred in connection with the property, or a rental payment of any amount whatever by the employee, would disqualify a residential property from being a "former business property", i.e. could these transactions cause a residence to be considered as used principally for the purpose of gaining or producing "gross revenue that is rent"? ...

It is the Department's view that paragraph 18(1)(1) would not have application to deny an outlay or expense in connection with a vessel essential to the business operations, all or substantially all the use of which is for business purposes.... 6. ...

Shinerock (613) 957-2108 19(1) Attention: August 29, 1990 Dear Sirs: Re: (1) Notice of Ways and Means Motion of November 24, 1989 (2) Subsection 55(2) of the income Tax Act (the "Act") We refer to your letter of August 1, 1990 in which you requested a technical interpretation on the application of the Notice of Ways and Means Motion that was tabled in the House of Commons on November 24, 1989 (the "Ways and Means Motion"), and the application of subsection 55(2) of the Act to the situation described below. 24(1) 24(1) In this connection, you understand that the expression "accumulated profits" means accounting profits computed on a consolidated basis with investments accounted for on a cost basis. ...

As we understand it, in connection with the settlement of a wrongful dismissal claim or action, or as a result of the decision of a court in such an action, an employer may agree to, or be required to, pay to the Plaintiff employee an amount on account of interest. ...