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., relating to the familiarization trips, it is our view that where the employee is not required by his employer to take these trips, expenses incurred in connection therewith should not be deductible. ...

Interpretation Bulletin IT-114 Your question on Interpretation Bulletin IT-114 also arises in connection with the above-noted issue of debentures and warrants. ...

Each of these "connections" is, in turn, statutorily defined (subsection 251(6) of the Act). ...

It is our position that the following two conditions must be met in order for payments for any services, including a hotline 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: (i) The acquisition of the services should be optional. ...

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 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. ...

In connection with your view, you have also mentioned that certain actions of the Taxpayer were undertaken to maximize the value of the property. ...

Answer In determining whether a property is a tax shelter for the purposes of section 237.1 of the Act, the calculation of deductible losses and other deductible amounts is to be made on a prospective basis based upon statements or representations made or proposed to be made in connection with that property. ... Is it the government's intention to force all related companies, regardless of, their inter-connection of business interests, to come to an agreement on how to allocate the capital deduction, or is it possible that a more reasonable middle ground could be reached by ensuring all associated corporations must allocate the deduction? ... The Queen [[1983] C.T.C. 20] 83 DTC 5041, when he described the expression as "probably the widest of any expression intended to convey some connection between two related subject matters". ...

We understand that, to the best of your knowledge and that of the above-referenced taxpayer, none of the issues involved in the ruling request is: (i) in an earlier return of the Company or a related person; (ii) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Company or a related person; (iii) under objection by the Company or a related person; (iv) before the courts; nor, (v) the subject of a ruling previously issued by the Directorate, other than in the Ruling. ...

To the best of your knowledge, and that of the taxpayers named above, none of the issues involved in this advance income tax ruling request: (a) is in an earlier return of the taxpayers or a related person; (b) is being considered by a tax services office or a taxation centre in connection with a previously filed income tax return of the taxpayers or a related person; (c) is under objection by the taxpayers or a related person; (d) is or has been before the courts; or (e) is the subject of a ruling previously considered by the Income Tax Rulings Directorate in respect of the taxpayers or a related person. ...

In concluding that there was sufficient inter-connection or integration with the business of production of silver that a gain from hedging activities could be considered to be income from that business, Mackay, J. commented in the case of Echo Bay Mines, 92 DTC 6437 (FCTD), that the gain from settlement of forward sales contracts could be considered as income from production only to the extent such contracts corresponded to the plaintiff's actual silver production. ...