Search - connection

It is our general position that the following two conditions must be met in order for payments for any services provided in connection with the use of computer software not to be considered part of the software license fee which is subject to Canadian withholding tax at source: a) The amount being paid for services must be defined in the contract and the payment for such services must be optional. ...

To the best of your knowledge and that of the officers and directors of the corporations named herein, none of the issues involved in this ruling is being considered by a District Office and/or Taxation Centre in connection with an income tax return already filed, and none of these issues is under objection or appeal. ...

Judicial penalties, which are imposed only in connection with a criminal proceeding, involve either a fine, imprisonment, or both, depending on the criminal offence. 44. ...

It is a word of large import, having several recognized meanings which vary greatly, according to the subject matter and the language in connection with which the word is used. ...

The loss on the sale is calculated as the original purchase price + capital additions- net selling price; (7) interest costs on bridge financing in the purchase of the new residence, provided that all reasonable efforts are exercised to dispose of the old residence; (8) reasonable interim living expenses at the new location while awaiting occupancy of permanent accommodation at the new location; (9) legal fees and land transfer tax for the purchase of a new residence; (10) adjustments and alterations to furniture and fixtures from the old residence to accommodate them in the new residence, including plumbing and electrical changes in the new residence for this purpose; (11) connection and installation charges for utilities, appliances and fixtures which existed at the old residence; (12) automobile licence, inspection and drivers permit fees where such items were owned at the former location; (13) the cost of revision to a will necessitated by the move; (14) moving costs of personal items and household effects including automobile, boat or trailer; (15) the cost of house hunting trips to the new location including child and pet care expenses; (16) expenses for moving an employee and household out of a remote place after the work has been completed. ...

In connection with the above payments, we note that Article XVIII of the Canada-United States Income Tax Convention deals with pension and defines "pension" to include amounts paid under a sickness, accident or disability insurance plan (Such a plan would generally include a wage loss replacement plan.). ...

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 connection with your other enquiry (our File No. 7-4387) regarding the eligibility of XXX EMR concluded, on the basis of their??? ...

In connection with your concern, you attached a copy of 4 pages of an 18 page agreement of purchase and sale dated XXXX between the Purchaser and XXXX (the "Vendor"). ...

In this connection it is to be noted that Arti- cle 5(1) of the Agreement would not allow the Canadian authorities to tax the proceeds of disposition in the event of such trading be- cause the income deriving therefrom must be regarded as being business income and not income from the property; this is the basic distinction made in the Income Tax Act (Canada) between business and property income. ...