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Your request follows a meeting held on November 30, 1989, at which Jack Szeszycki of this Division attended, between representatives of Revenue Canada, Taxation, National Health and Welfare and the Background 24(1) Generally, individuals that will be entitled Co assistance under the Wage Policy are already receiving some level of social assistance in connection with their disability. ...

A ruling request must also contain a statement as to whether any of the issues involved are to the best of a taxpayer's knowledge being considered by a District Office and/or Taxation Centre in connection with a tax return already filed, or if any of the issues are under objection. ...

A ruling request must also contain a statement as to whether any of the issues involved are to the best of a taxpayer's knowledge being considered by a District Office and/or Taxation Centre in connection with a tax return already filed, or if any of the issues are under objection. ...

In the case of principal shareholder-managers of a corporation, the Department generally will not consider their remuneration excessive in the following circumstances: the corporation's normal practice is to distribute its profits to these individuals in the form of bonuses or additional salary, or the corporation has a policy of declaring bonuses to the shareholder- managers for corporate profits stemming from special knowledge, skills or connections, etc. of that person. ...

A carried on an oil and gas production business in Canada and, in connection therewith, has received payments from pipeline companies under the "take or pay" provisions of the governing gas purchase agreements. 2. ...

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 the employee/manager or his dependents. ...

It is our general position that the following two conditions must be met in order for payments for maintenance service fees, provided in connection with the use of computer software, not to be considered part of the software licence fee which is subject to Part XIII tax: 1. ...

If the latter course of action is taken, we suggest that the Crown should pay all solicitor-client costs in connection with such determination because after the outcome thereof the Crown would likely discontinue its appeal in this matter. ...

Inasmuch as we are not certain of the exact nature of the "acquisition fee" that you have referred to, we cannot provide a definitive reply, however, we would note that legal and accounting fees incurred by a taxpayer in connection with the purchase or sale of shares held by a taxpayer as capital property are included as a component of the adjusted cost base (i.e. cost amount) of the shares or deducted from the sale proceeds as disposal costs, as applicable. ...

As long as All or substantially all of the duties performed by the employee are in connection with a contract under which the specified employer carries on a business with respect to any of the activities referred to in Clauses 122.3(1)(b)(i)(A) to (C) of the Act, the employee would qualify for the Overseas Employment Tax Credit provided that other conditions referred to in subsection 122.3(1) of the Act are met. ...