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23 October 1991 Administrative Letter 912346 F- Penalty Provisions in Connection with Collection Procedures Unedited CRA Tags 239(1(d),162(7)(b), 159(2),159(3) Application of 239(1(d) & 162(7)(b) to 159(2) & (3) Further to our telephone conversation of October 18, 1991, withEr. ... Prosia, he indicated that to the best of his knowledge, the above noted penalty provisions are not given consideration in connection with the collection procedures instituted as a result of the application of 159(3). ...

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.  ...

Accordingly, an individual who is not an employee, e.g. a self employed architect, is not eligible for the deduction form tax under this section. (2)     The individual must have performed all or substantially all the duties of his employment in one or more countries other than Canada in connection with a contract under which the specified employer carried on business in such other country or countries with respect to any construction, installation, agricultural or engineering activity.  ... The individual must have performed his duties of employment in the other country or countries in connection with the employer's contract.  Thus, for example, individuals whose duties of employment are administrative office functions, e.g. bookkeeping, for their employer will be eligible if they are "in connection with" the performance by the employer of a contract of the kind described above. ...

The Technical Notes issued by the Department of Finance in 1983, when the the Overseas deduction was replaced by the OETC, stated "(t)he new credit is available to individuals resident in Canada working abroad for six consecutive months or longer for a specified employer in connection with a resource, construction  installation, agricultural or engineering project".  ... E had to be employed by a specified employer and performed all or substantially all the duties of employment in a country other than Canada in connection with a contract under which the specified employer carried on business in such country.  ... F is employed by a specified employer  he would be eligible to claim the OETC provided the employer carried out the drilling activities itself outside Canada in connection with the two contracts and he performed all or substantially all the duties of his employment outside Canada.  ...

Short   (613) 957-2134 November 6, 1989 Dear Sirs: Re:  Automobile Allowances This is in reply to your letter dated July 14, 1989, wherein you have requested an interpretation of subparagraph 6(1)(b)(v) and paragraph 18(1)(r) of the Income Tax Act (the "Act") in connection with the following situation: A commission based employee receives an automobile allowance that is in excess of 27 cents for the first 5,000 kilometres and 21 cents for the remaining kilometres.  ... By virtue of subparagraph 6(1)(b)(v) of the Act, a reasonable allowance 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, is excluded from employment income. ...

Furthermore, as you are aware, the views of the U.K. tax authorities (ie. in regard to the meaning of "activities" and "in connection with" as used in Article XXVIIA) were requested by Provincial and International Relations Division (at your request) and their reply basically confirmed the position we had taken. ...

In cases where the only substantial connection a corporation has with a particular country is that the meetings of the Board of Directors are arranged there, the case would be examined carefully to determine where in fact control is exercised which may likely be elsewhere.  ... Accordingly, when analysing the personal and economic ties to both countries, it is not enough to simply weigh or count the number of factors or connections to each state but to determine the depth of the roots of one's centre of vital interests which encompasses looking at the factors over a period of time. ...

The comments in this letter are of a general nature only and do not take into account considerations that might arise in connection with a specific transaction or event. ...

Your request follows a meeting held on November 30, 1989, at which Jack Szeszycki of this Division attended, between representatives of Revenue Canada, Taxation, National Health and Welfare and the 24(1) Background 24(1) Generally, individuals that will be entitled to assistance under the Wage Policy are already receiving some level of social assistance in connection with their disability.  ...

Evanson Canadian Resource Property- Partnership Interests This is in reply to your memorandum of July 21, 1992 in which you requested our views on your draft memorandum to the Calgary District Office in connection with 24(1) During your recent discussion with Jim Gauvreau, it was agreed that it is not necessary for us to comment on your draft memorandum; instead, we would address the principal issue which concerns whether an interest in a partnership should be considered as a Canadian resource property for purposes of the successor rules. ...