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The monthly allowance is deemed to be in excess of a reasonable amount for two reasons: first, the allowance is not based solely on the number of kilometres for which the motor vehicle is used in connection with or in the course of his office or employment (subparagraph 6(1)(b)(x) of the Act) and secondly, because the clergyman is receiving both an allowance in respect of the business use of the motor vehicle and is reimbursed for expenses in respect of the same business use (subparagraph 6(1)(b)(xi) of the Act). ... The preamble to subparagraphs 6(1)(b)(x) and (xi) of the Act states that "for the purposes of subparagraphs (v), (vi) and (vii.1), an allowance received in the year by the taxpayer for use of a motor vehicle in connection with or in the course of his office or employment shall be deemed to be in excess of a reasonable amount... ...

Where the Canadian cable TV companies pick up distant signals which are transmitted from films or video tapes, any payments in respect of the retransmission of such signals will fall within paragraph 212(5)(b) of the Income Tax Act (the "Act") as payments for the use of a film, video tape or other means of reproduction for use in connection with television. Where the signals of live broadcasts of sporting or other events are retransmitted by Canadian cable TV companies, such payments will also fall within the wording "or other means of reproduction for use in connection with television" and be subject to withholding tax in Canada when paid to non-residents of Canada. ...

7 May 1991 Income Tax Severed Letter- Split Dollar Life Insurance Unedited CRA Tags none Dear Sirs: Re: Split Dollar Life Insurance This is in reply to your letter of February 12, 1991 in which you requested our views as to whether a shortened premium paying period in connection with split dollar life insurance arrangements would alter the Department's established positions on the tax treatment of these arrangements. ... This position only applies where the corporation is entitled to the cash surrender value of the policy on its termination or to a portion of the amount payable under the original policy on death equal to its cash surrender value immediately before death, as well as to dividends that arise in connection with the policy. ...

18 April 1983 Income Tax Severed Letter 5-1787D Unedited CRA Tags 39(1), 39(2), 95(1)(b), 95(2)(f) We refer to our conversation of April 7 in connection with the above matter. ... This particular problem has arisen in connection with a subsidiary of Caminco and at this time they have disputed the FAPI gain but not on the basis set out herein. ...

Subsection 20(10) of the Income Tax Act permits a deduction in computing a taxpayer's income from a business for amounts paid by the taxpayer as or on account of expenses incurred in attending, in connection with the business, not more than two conventions held during the year by a business or professional organization at a location that may reasonably be regarded as consistent with the territorial scope of that organization. ... As a result, if the taxpayer meets the requirements in paragraph 20(10) that the expenses be incurred by the taxpayer and that the attendance at the convention be in connection with the taxpayer's business, he should be entitled to deduct expenses incurred to attend a convention held by a Canadian organization anywhere in the United States. ...

Subsection 20(10) of the Income Tax Act permits a deduction in computing a taxpayer's income from a business for amounts paid by the taxpayer as or on account of expenses incurred in attending, in connection with the business, not more than two conventions held during the year by a business or professional organization at a location that may reasonably be regarded as consistent with the territorial scope of that organization. ... As a result, if the taxpayer meets the requirements in paragraph 20(10) that the expenses be incurred by the taxpayer and that the attendance at the convention be in connection with the taxpayer's business, he should be entitled to deduct expenses incurred to attend a convention held by a Canadian organization anywhere in the United States. ...

In this connection, as set out in paragraph 9 of IT-159R2, the determination of when a debt becomes a bad debt is a question of fact. ... In this connection it is our view that a taxpayer, in the circumstances described above, would be able to avail himself of the provisions of subsection 50(1) of the Act when it can be shown that the whole amount of the debt is uncollectable or when a portion of it has been settled and the remainder is uncollectable. ...

All contributions made under the EBP after the establishment of the Statutory Arrangement and all property that can reasonably be considered to derive from those contributions are deemed to be property held in connection with the Statutory Arrangement and not in connection with the existing arrangement. ...

The monthly allowance is deemed to be in excess of a reasonable amount for two reasons: first, the allowance is not based solely on the number of kilometres for which the motor vehicle is used in connection with or in the course of his office or employment (subparagraph 6(1)(b)(x) of the Act) and secondly, because the clergyman is receiving both an allowance in respect of the business use of the motor vehicle and is reimbursed for expenses in respect of the same business use (subparagraph 6(1)(b)(xi) of the Act). ... The preamble to subparagraphs 6(1)(b)(x) and (xi) or the Act states that "for the purposes of subparagraphs (v), (vi) and (vii.1), an allowance received in the year by the taxpayer for use of a motor vehicle in connection with or in the course of his office or employment shall be deemed to be in excess of a reasonable amount... ...

8 December 1982 Income Tax Severed Letter XXXX December 8, 1982 For the attention of XXXX Dear Sirs: The undersigned hereby authorizes you to apply to the Department of National Revenue for an advance income tax ruling in connection with the proposed disposition of his shares of XXXX Yours very truly, XXXX ...