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Tremblay (613) 957-2095 Dear Sirs: This is in reply to your letter of August 10, 1989, requesting our views on the tax treatment of several arrangements which charitable organizations are either using or contemplating using in connection with their fund raising activities. ...

On the assumption that the management staff are not "employed in connection with the selling of property or negotiating of contracts", they would not be able to exclude the travelling allowance from their income under paragraph 6(1)(b)(v) of the Act. ...

The basis for the position in paragraph 44 of IT-145R allowing most of the activities performed in connection with publication of a newspaper to be considered qualifying activities arose as a result of the Department losing the court case The St. ...

In support of this view, they have mentioned the following: (a) A portion of each loan will be forgiven absolutely as the government's rights to collect it will be extinguished; and (b) Paragraph 9 of IT-455R, which discusses government sponsored programs in connection with the acquisition of fishing vessels or equipment, states that the provisions of section 80 will apply if a borrower's loan is settled or extinguished for a lesser amount than the principal owing. ...

For example, in the case of non-commercial activities of a band or tribal council representing Indians on a reserve or an organization controlled by one or more of these entities and dedicated to the social, political, economic or cultural development of those Indians which is resident on a reserve, it is reasonable to conclude that there is sufficient connection to a reserve to warrant an exemption. ... In each of these cases, sufficient connection exists to a reserve to locate the income there and grant the tax exemption. ...

To compensate Subco for the costs it incurs in relation to the employees, the net income of PartnershipA will be first allocated to Subco in an amount equal to the sum of all reasonable expenses and costs incurred by Subco in connection with the performance of its duties under the PartnershipA Agreement, including the provision of its employees to PartnershipA. ... The articles will provide that Aco Class A Common Shares may only be issued in connection with a stock dividend, a stock split or similar event that affects all holdings of Aco Class A Common Shares in the same manner, on a per share basis. ...

Where an individual has maintained Canadian residence status, the O.E.T.C. will apply where "throughout any period of more than 6 consecutive months that commenced before the end of the year and included any part of the year" the individual was employed by a specified employer (as defined in section 122.3) and performed all or substantially all the duties of his employment in one or more countries other than Canada in connection with a contract referred to in subparagraph 122.3(1)(b)(i) of the Act or for the purpose of obtaining such a contract on behalf of the employer. ... Subsection 122.3(1) requires that the individual "throughout" the qualifying period performed all or substantially all the duties of his employment in one or more countries other than Canada for a specified employer in connection with a contract referred to in subparagraph 122.3(1)(b)(i) of the Act or for the purpose of obtaining such a contract on behalf of the employer. ...

Expenses incurred in connection with property income do not qualify. Generally, plan set-up costs incurred by an employer who earns business income would be for the purpose of producing income from that business and (to the extent not otherwise deductible) would generally qualify for ECE treatment. ... If accounts become payable in connection with the repayment of tax credits, money shall be paid out of the account to the Minister of Finance and Corporate Relations. ...

We also acknowledge your letters of XXXXXXXXXX and our telephone conversations in connection herewith. ... To the best of your knowledge and that of the officers and directors of XXXXXXXXXX, none of the issues involved in this advance income tax ruling request is under objection or appeal or is being considered by any of the District Taxation Offices or Taxation Centres of Revenue Canada, Taxation (the “Department”) in connection with any tax return already filed. ...

Where an individual has maintained Canadian residence status, the 0.E.T.C. will apply where “throughout any period of more than 6 consecutive months that commenced before the end of the year and included any part of the year” the individual was employed by a specified employer (as defined in section 122.3) and performed all or substantially all the duties of his employment in one or more countries other than Canada in connection with a contract referred to in subparagraph 122.3(1)(b)(i) of the Act or for the purpose of obtaining such a contract on behalf of the employer. ... Subsection 122.3(1) requires that the individual “throughout” the qualifying period performed all or substantially all the duties of his employment in one or more countries other than Canada for a specified employer in connection with a contract referred to in subparagraph 122.3(1)(b)(i) of the Act or for the purpose of obtaining such a contract on behalf of the employer. ...