Search - connection

To the best of your client's and your knowledge, none of the issues involved in this ruling application is being considered by a Tax Services Office or a Taxation Centre in connection with any tax return already filed and none of the issues is under objection. ...

You have advised and you confirm, to the best of your knowledge, that none of the issues involved in this ruling request is being considered by a Tax Services office or a Tax Centre in connection with a tax return already filed and none of the issues is under objection. ...

Generally, and as stated above, payments made by an employer to an employee in connection with a loss or termination of employment, whether or not received as damages or pursuant to an order of a competent tribunal, are characterized as a retiring allowance. ...

It is our general position that the following two conditions must be met in order for payments for any services provided in connection with the use of computer software not to be considered part of the software license fee which is subject to Canadian withholding tax at source: a) The amount being paid for services must be defined in the contract and the payment for such services must be optional. ...

Paragraph 6 of Article XI of the US Treaty states that "Where, however, 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 or a fixed based in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment or fixed base, then such interest shall be deemed to arise in the State in which the permanent establishment or fixed base is situated and not in the State of which the payer is resident". ...

The word "conjunction" is defined in The Oxford English Dictionary to mean "joining together, marriage union, connextion of ideas,... the action of conjoining; the fact or condition of being conjoined; union, connexion, combination... ...

the written evidence authorizing the applicant to act for the taxpayer or in the advance ruling request should be a statement whether any of the issues involved in the ruling request are, to the best of the 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. ...

We trust the foregoing is of assistance and return herewith the orange file and all of the materials that you provided to us in connection with this matter. ...

Travel expenses incurred in connection with the XXX would, in our view, not satisfy this condition. ...

Our Comments In order for the partnership to be considered to be a tax shelter, one must regard "statements or representations made or proposed to be made in connection with the property," according to the definition of tax shelter in subsection 237.1(1). ...