Search - connection

You have advised that, to the best of the knowledge of yourself and that of XXXXXXXXXX, none of the issues involved in this request for an advance income tax ruling is in an earlier return of income of XXXXXXXXXX or any related person, is under objection or appeal, or is being considered by a taxation services office or taxation centre of Revenue Canada in connection any tax return already filed. ...

In this connection, we agree that it would also be reasonable to reduce the income taxes on the $200,000 as otherwise determined by a pro rated portion (based on the number of days in the 1989 stub period as a proportion of the total number of days in B Co.'s 1989 taxation year) of 16% of the least of the amounts referred to in subsection 125(1) of the Act, but subject to subsections 125(2) and (3) of the Act. 2. ...

For the SR & ED to be related to a business of the taxpayer, there must be some connection or link between the taxpayer's business carried on at the time the expenditure is made and the SR & ED carried on. ...

It further stated that the real question is whether or not there are any inter-connection, any interlacing, any interdependence, any unity at all embracing those two businesses. ...

In connection with your observation that the word "indebtedness" has been substituted for the words "bond, debenture, bill, note, mortgage, hypothec or similar obligation" in the definition of "qualified small business corporation share" and "small business corporation" in subsections 110.6(1) and 248(1) of draft legislation released by the Department of Finance on July 13, 1990 (now Bill C-18 which received First Reading on May 30, 1991), we agree that "indebtedness" has a more general meaning than the words it is replacing. ...

The fact that a corporation, carrying on an active business and holding certain property (i.e. investments) unrelated to the business, uses the income from property in connection with the operation of the active business does not mean that the property is "incident to or pertains to" the active business. ...

If, in fact, that cargo handling operation had developed to a stage where it was beyond any reasonable requirements of the company's own ships, it would seem appropriate to treat it as a separate business and, in the context of the question at hand, to exclude those revenues arising in connection with cargo services provided to the other shipowners. ...

In general terms they are as follows: (a) it must not, in the opinion of the Minister, be a charity; (b) it must be organized exclusively for social welfare, civic improvement, pleasure, recreation or any other purpose except profit; (c) it must in fact be operated exclusively for the same purpose in (b) for which it was organized or for any of the other purposes mentioned in (b); and (d) no part of its income may be paid, payable or otherwise made available for the personal benefit of any proprietor, member or shareholder, except in connection with the promotion of amateur athletics in Canada. ...

The above review of written material supports our position that the word 'contractor' is most commonly used in connection with the construction industry. ...

Summary Our review of the legislation in connection with the "Frontier Exploration Allowance" leads us to the conclusion that we, at the District office level, are not in a position to accept revised T-3015's, the possible need for which arises from audit reassessment adjustments. ...