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MNR [[1974] C.T.C. 209] (supra), is that the expenses are incurred "... in connection with... ... As emphasized by the preamble to subsection 20(1) there must be a clear connection between the amount to be deducted and the source of the borrowing. ... Deductibility as a discount XXX Expenses related to financial reporting In our opinion, expenditures, in any, incurred to issue financial reports to shareholders to inform them of the loan restructuring should be deductible under subparagraph 20(1)(g)(iii), including the cost of obtaining the necessary legal and financial advice in connection with the issuance of financial reports. ...

As indicated in our telephone discussion with you on April 25, we do not intend to communicate with XXX in connection with this matter other than to advise them that we shall be providing you with our views. Facts It is our understanding that the relevant facts in connection with this matter are as follows: 1. ... Ct.), dismissed on another issue, (1969), 23 DTC 5203 (SCC) determined that the length of time during which a debt is outstanding is irrelevant and thus seems to have determined that whether or not a debt is "permanent" financing is irrelevant for purposes of determining whether foreign exchange gains and losses in connection therewith are on income account or capital account. ...

Loveday 5-8295 24(1) Individual Policyholders' Taxation on Surrenders of Life insurance Policies We are writing in connection with your memoranda of June 22 and July 31, 1989. ... Abdulhusein and B.Dodd, October 12, 1989), we are providing you with our comments on 24(1) April 20, 1989 letter and understand that you will reply directly to: We apologize for the delay. 24(1) has requested the Department's views in connection with a worksheet for the calculation of the amount to be included in income under subsection 148(l) of the income Tax Act (the "Act"). 24(1) Item 1) The overall approach being taken by 24(1) (as evidenced by items 1), 2) and 3) collectively), appears to be based somewhat on the method described in the Department's paper on the calculation of the adjusted cost basis ("ACB") for life insurance policies (prepared by G. ... The second component of Item 3), being policy loans after March 31, 1978 was discussed above in connection with item 2) The third component of Item 3), being annual dividends after March 31, 1977 (the date should actually be the MTA), including, termination dividends, and the descriptions thereof contained in 24(1) letter, reflect the appropriate treatment for policy under the Act. ...

The first exception that would apply to automobile allowances is provided for in subparagraph 6(1)(b)(v) of the Act, which exempts from income reasonable allowances for travelling expenses received by an employee from his employer in respect of a period when he was employed in connection with the selling of property or negotiating of contracts for his employer. The second exception for automobile allowances is subparagraph 6(1)(b)(vii.1) of the Act which exempts allowances (not in excess of reasonable amounts) for the use of a motor vehicle received by an employee (other' than an employee employed in connection with the selling of property or negotiating of contracts for his employer) from his employer for. travelling in the performance of the duties of his office or employment. However, under subparagraph 6(1)(b)(x) of the Act, a motor vehicle allowance is deemed to be in excess of a reasonable amount where the measurement of the use of the vehicle for the purpose of the allowance is not based solely on the number of kilometres for which the motor vehicle is used in connection with or in the course of his office or employment. ...

Using this approach 24(1) 24(1) Deductibility under paragraph 20(1)(e) 24(1) The test in Yonge-Eglinton Building Ltd. v MNR (supra), is that the expenses are incurred "... in connection with... ... " the borrowing. 24(1) As emphasized by the preamble to subsection 20(1) there must be a clear connection between the amount to be deducted and the source of the borrowing. 24(1) We also note 19(1) quotation of a passage from the same case which indicates that paragraph 20(1)(e) has a very broad scope because the section specifically excludes commissions and bonuses and payments as or on account of principal and interest. ... Deductibility as a discount 24(1) Expenses related Co financial reporting In our opinion, expenditures, if any, incurred to issue financial reports to shareholders to inform them of the loan restructuring should be deductible under subparagraph 20(1)(g)(iii), including the cost of obtaining the necessary legal and financial advice in connection with the issuance of financial reports. ...

(Quotation is from the preamble of the provisions of subsection 62(1)) In 1972, Technical Interpretations Division advised Administrative Policy Branch that, although the allowance provided to Revenue Canada employees in respect of moving expenses was taxable within the strict interpretation of paragraph 6(1)(b), the allowance could be considered non-taxable if the employee was required to certify that expenses in the amount of the allowance were incurred in connection with the move for which no other reimbursement was available. ... However, since the inception of Section 62 we have always maintained that, where a member of the Armed Forces claimed moving expenses for which he was not fully reimbursed, he must reduce this claim by the amount of the allowance that was received in connection with his employer imposed relocation. ... You are now prepared to take the position that the allowance of either $150 or $500 paid by the Department of National Defence and the allowance of either $100, $200 or $500 paid to employees of other Federal Government Departments for moving expenses that are not deductible under section 62 should not be included in income for purposes of paragraph 62(1)(g) where the allowance is considered to be a non-taxable reimbursement because the employee certifies that expenses in the amount of the allowance were incurred in connection with the move for which no other reimbursement was available. ...

Paragraph 110.7(1)(d) of the Act states, in part, that "... there may be deducted... an amount received... in the year by him in respect of his employment... in respect of travelling expenses incurred by him, to the extent that the amount received... is included and is not otherwise deducted in computing his income... and the travelling expenses were incurred in connection with... not more than two trips made in the year... ... From this wording it is our opinion that there must be a connection between the actual travelling expenses incurred by the taxpayer and the amounts paid by the employer to defray those costs. ... In addition a deduction may be claimed with respect to travelling expenses incurred in connection with not more than two trips made in a calendar year". ...

10 August 1989 Income Tax Severed Letter 5-8424- Private health services plan Unedited CRA Tags none XXX Private Health Services Plan We are writing in connection with your letter of July 17, 1989 announcing the creation of a private health services plan by XXX. ...

23 April 1974 Income Tax Severed Letter April 23, 1974 We have received you letters dated March 25 and April 16 in connection with "a Danish resident" and the disposition of taxable Canadian property. ...

Szeszycki (613) 957-2103 August 10 1989 24(1) Private Health Services Plan We are writing in connection with your letter of July 17, 1989, announcing the creation of a private health services plan by 24(1)24(1) Although no formal notification to, or registration with, this Department is required in respect of the creation of private health services plans, we acknowledge receipt of your letter and confirm that no other reporting requirements exist. for Director Small Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch ...