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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 base 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". ...

He stated at page 89 "I think the real question is, was there any inter-connection, any interlacing, any inter-dependence, any unity at all embracing those two businesses;". ...

As the taxpayer does not appear to be "employed in the year in connection with the selling of property or negotiating of contracts for his employer", the deduction set out in paragraph 8(1)(f) of the Income Tax Act (the "Act") would not be available. 2. ...

In this connection, the special release to IT-339R referred to above also proposes a revision of paragraph 14 as follows: 14. ...

., shares issued in connection with the Scientific Research and Experimental Development Tax Credit the potential exists that the paid-up capital for income tax purposes may be less than the stated capital reported on the financial statements. ...

It is not our view that an acquisition will necessarily be considered to have occurred in contemplation of a subsequent butterfly reorganization merely because it is intended, at the time of the acquisition, to carry out the butterfly reorganization; instead, we consider that there must be some casual connection between the acquisition and the later reorganization. ...

You advise that although the taxpayers received the amounts (damages and accrued interest) under the judgment in 1984, they have not reported any amounts on their 1984 returns in this connection except for interest earned on these amounts after they received payment. ...

It is our view, therefore, that in the case of the closure of the XXXX affected employees are receiving a non-accountable allowance in connection with their relocation to other job situations and that such an allowance is taxable under the provisions of paragraph 6(1)(a) of the Act. ...

Consistent with these comments, it is also our view that the purchaser would not be allowed to deduct any costs incurred in connection with the capital obligation. ...

However, this position applies only where the corporation pays premiums equal to the annual increase in the policy's cash surrender value and 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 the dividends that arise in connection with the policy (or anything substituted therefore). ...