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We agree with this connection. However, we would not consider a finding that a person did not have an interest in the property of a trust as determinative of whether that person is a person beneficially interested in the trust. ...

In connection with these comments, we also note that the non-resident is considered to have sold the apartment at its fair market value at the time of the gift (See page 17 of the enclosed Capital Gains Guide). ...

Since “exempt loss” and “taxable loss” are only defined (in paragraphs 5907(1)(c) and 5907(1)(j) respectively) in connection with a foreign affiliate of a corporation, no amounts would be determined under those provisions in respect of a foreign affiliate of an individual. ...

Further, it is our opinion that the phrase "a film, videotape or other means of reproduction for use in connection with television" as used in the Act will generally be construed in a broad manner: that is, it will not be limited to television broadcasting as in the Convention. ...

Astaphan (613) 957-2119 XXX Attention: XXX July 17, 1989 Dear Sirs: Re: Shareholder Benefits- Use by Shareholder of a Corporate-Owned Property This letter is in reply to your letter dated January 18, 1989 wherein you raised several questions in connection with the term "sole purpose corporation" used by the Department in the context of Question 20 of the 1980 Revenue Canada Round Table and Question 14 of the 1985 Revenue Canada Round Table. ...

It is not known whether any of such individuals have any other connection with Canada. 9. ...

The second sentence of Article XI(6) provides an exception to this rule are the following conditions are met: 1) The payor has a permanent establishment or fixed base in another State in connection with which the indebtedness was incurred which gave rise to the interest payments. 2) Such interest is borne by such permanent establishment or fixed base. ...

In connection with this question1 you refer to the quotation by the Supreme Court of Canada in Re Alberta Legislation, [1938] 2 D.L.R. 81 at 99, from Macleod, Theory of Credit at pp. 368-9, as follows: "... it is the entry to the credit of the customer which, in the technical language of modern banking is termed a Deposit... ...

Maintenance Service Contract It is our general position that the following two conditions must be net in order for payments for any services, including a hot line service, 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. ...

In this regard, we would require details about the type of mobile home and its connection (if any) to the land situated thereon. ...