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The employees are not, for the most part, employed in connection with the selling of property or negotiating of contracts for Company A. 5. ...

At page 89 it further stated that the real question is whether or not there are any inter-connection, any interlacing, any inter-dependence, any unity at all embracing those two businesses. ...

In addition, either included in 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. ...

X Co. will not hold securities in connection with any one transaction in excess of 25% of the total capital of X Co. ...

You enclosed material forwarded to you by the Hamilton District Office concerning several employee benefit plan (EBP) issues resulting from a XXX (1) XXXX (2) XXX (3) XXX In connection with (1) above, the D.O. believes the plan is operating in accordance with the Income Tax Act (the "Act") but is concerned with a number of points. ...

If his gains arise in this connection, he would also be considered to be a trader and thus not allowed to make a subsection 39(4) election. ...

Travel expenses incurred in connection with the 24(1) 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). ...

You indicate that the number of investors would be approximately fifty. of which 80% would not be related to each other and would not have business connections with each other. ...

If the payments are regarded as a "royalty" as defined in Article XII(4) of the Convention, they would not be exempt from Part XIII tax by virtue of the exception in Article XII(3) of the Convention provided that they constitute royalties in respect of motion pictures and works on film, videotape or other means of reproduction for use in connection with television. ...