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Paragraph 20(1)(ee) cannot apply if a taxpayer owns or will own the pipe that is used in making the service connection. ... In addition, the amount paid for a service connection must be made to a person with whom the taxpayer deals at arm's length and that person must also supply the goods or services for which the service connection has been made (although no amount is deductible under paragraph 20(1)(ee) for the cost of supplying those goods or services). ... New ¶ 10 provides a discussion on the tax treatment of pipes that are used to provide utility service connections. ...

Paragraph 20(1)(ee) cannot apply if a taxpayer owns or will own the pipe that is used in making the service connection. ... In addition, the amount paid for a service connection must be made to a person with whom the taxpayer deals at arm's length and that person must also supply the goods or services for which the service connection has been made (although no amount is deductible under paragraph 20(1)(ee) for the cost of supplying those goods or services). ... New ¶ 10 provides a discussion on the tax treatment of pipes that are used to provide utility service connections. ...

However, paragraph XXIX A(3) does not apply to income derived in connection with a trade or business in the resident state unless that trade or business is substantial in relation to the activity carried on in the other state. ... Meaning of “in connection with” In determining whether Canadian-source income has been derived by a US resident in connection with an active trade or business in the United States, the CRA will be guided by the commentary set out in the technical explanation to the fifth protocol and the 2006 US model technical explanation. 35 In general terms, we would consider Canadian-source income to be derived “in connection with” a trade or business in the United States if the income is derived from an activity in Canada that is a part of, or is complementary to, the trade or business in the United States. ... Example The following example is intended to illustrate a situation in which Canadian-source dividends and taxable capital gains would be considered to be derived in connection with an active trade or business carried on in the United States by a US-resident corporation (USco). ...

However, paragraph XXIX A(3) does not apply to income derived in connection with a trade or business in the resident state unless that trade or business is substantial in relation to the activity carried on in the other state. ... Meaning of “in connection with” In determining whether Canadian-source income has been derived by a US resident in connection with an active trade or business in the United States, the CRA will be guided by the commentary set out in the technical explanation to the fifth protocol and the 2006 US model technical explanation. 35 In general terms, we would consider Canadian-source income to be derived “in connection with” a trade or business in the United States if the income is derived from an activity in Canada that is a part of, or is complementary to, the trade or business in the United States. ... Example The following example is intended to illustrate a situation in which Canadian-source dividends and taxable capital gains would be considered to be derived in connection with an active trade or business carried on in the United States by a US-resident corporation (USco). ...

Any comments relating to specific ITs can be sent by email to bulletins@ccra.gc.ca List of Archived Interpretation Bulletins The publications listed below will now be found in the Archived Income Tax Interpretation Bulletins section of the CCRA Web site at the following address: www.ccra.gc.ca/menu/ITSA-e.html IT-111R2, Annuities Purchased from Charitable Organizations IT-150R2, Acquisition From a Non-resident of Certain Property on Death or Mortgage Foreclosure or by Virtue of a Deemed Disposition IT-156R, Feedlot Operators IT-183, Foreign Tax Credit – Member of a Partnership IT-254R2, Fishermen – Employees and seafarers – Value of rations and quarters IT-314, Income of Dealers in Oil and Gas Leases IT-316, Awards for Employees' Suggestions and Inventions IT-317R, Capital Cost Allowance – Radio and Television Equipment IT-319, Cost of Obligations Owned on December 31, 1971 IT-321R, Insurance Agents and Brokers – Unearned Commissions IT-323, Sale of Mortgage Included in Proceeds of Disposition of Depreciable Property IT-338, Partnership Interests – Effects on Adjusted Cost Base Resulting from the Admission or Retirement of a Partner IT-370, Trusts – Capital Property Owned on December 31, 1971 IT-374, Meaning of "Settlor" IT-388, Income Bonds Issued by Foreign Corporations IT-392, Meaning of the term "share" IT-409, Winding-up of a non-profit organization IT-446R, Legacies IT-449R, Meaning of "Vested Indefeasibly" IT-452, Utility Service Connections IT-461, Forfeited Deposits IT-483, Credit Unions IT-488R2, Winding-up of 90% Owned Taxable Canadian Corporations IT-493, Agency Cooperative Corporations Income Tax Publications Subscriber List The CCRA is introducing a new electronic mailing list to advise our subscribers of all new income tax related technical publications (ITs, TNs, ICs), as well as other matters of interest to tax professionals and taxpayers. ...

Any comments relating to specific ITs can be sent by email to bulletins@ccra.gc.ca List of Archived Interpretation Bulletins The publications listed below will now be found in the Archived Income Tax Interpretation Bulletins section of the CCRA Web site at the following address: www.ccra.gc.ca/menu/ITSA-e.html IT-111R2, Annuities Purchased from Charitable Organizations IT-150R2, Acquisition From a Non-resident of Certain Property on Death or Mortgage Foreclosure or by Virtue of a Deemed Disposition IT-156R, Feedlot Operators IT-183, Foreign Tax Credit – Member of a Partnership IT-254R2, Fishermen – Employees and seafarers – Value of rations and quarters IT-314, Income of Dealers in Oil and Gas Leases IT-316, Awards for Employees' Suggestions and Inventions IT-317R, Capital Cost Allowance – Radio and Television Equipment IT-319, Cost of Obligations Owned on December 31, 1971 IT-321R, Insurance Agents and Brokers – Unearned Commissions IT-323, Sale of Mortgage Included in Proceeds of Disposition of Depreciable Property IT-338, Partnership Interests – Effects on Adjusted Cost Base Resulting from the Admission or Retirement of a Partner IT-370, Trusts – Capital Property Owned on December 31, 1971 IT-374, Meaning of "Settlor" IT-388, Income Bonds Issued by Foreign Corporations IT-392, Meaning of the term "share" IT-409, Winding-up of a non-profit organization IT-446R, Legacies IT-449R, Meaning of "Vested Indefeasibly" IT-452, Utility Service Connections IT-461, Forfeited Deposits IT-483, Credit Unions IT-488R2, Winding-up of 90% Owned Taxable Canadian Corporations IT-493, Agency Cooperative Corporations Income Tax Publications Subscriber List The CCRA is introducing a new electronic mailing list to advise our subscribers of all new income tax related technical publications (ITs, TNs, ICs), as well as other matters of interest to tax professionals and taxpayers. ...

Any comments relating to specific ITs can be sent by email to bulletins@ccra.gc.ca List of Archived Interpretation Bulletins The publications listed below will now be found in the Archived Income Tax Interpretation Bulletins section of the CCRA Web site at the following address: www.ccra.gc.ca/menu/ITSA-e.html IT-111R2, Annuities Purchased from Charitable Organizations IT-150R2, Acquisition From a Non-resident of Certain Property on Death or Mortgage Foreclosure or by Virtue of a Deemed Disposition IT-156R, Feedlot Operators IT-183, Foreign Tax Credit – Member of a Partnership IT-254R2, Fishermen – Employees and seafarers – Value of rations and quarters IT-314, Income of Dealers in Oil and Gas Leases IT-316, Awards for Employees' Suggestions and Inventions IT-317R, Capital Cost Allowance – Radio and Television Equipment IT-319, Cost of Obligations Owned on December 31, 1971 IT-321R, Insurance Agents and Brokers – Unearned Commissions IT-323, Sale of Mortgage Included in Proceeds of Disposition of Depreciable Property IT-338, Partnership Interests – Effects on Adjusted Cost Base Resulting from the Admission or Retirement of a Partner IT-370, Trusts – Capital Property Owned on December 31, 1971 IT-374, Meaning of "Settlor" IT-388, Income Bonds Issued by Foreign Corporations IT-392, Meaning of the term "share" IT-409, Winding-up of a non-profit organization IT-446R, Legacies IT-449R, Meaning of "Vested Indefeasibly" IT-452, Utility Service Connections IT-461, Forfeited Deposits IT-483, Credit Unions IT-488R2, Winding-up of 90% Owned Taxable Canadian Corporations IT-493, Agency Cooperative Corporations Income Tax Publications Subscriber List The CCRA is introducing a new electronic mailing list to advise our subscribers of all new income tax related technical publications (ITs, TNs, ICs), as well as other matters of interest to tax professionals and taxpayers. ...

Costs incurred in connection with attending a convention or a business meeting can receive different tax treatment from the costs of attending a training course. ... However, expenses incurred in connection with a full-time course of longer duration may, in certain circumstances, be considered reasonable. ... Claims in connection with training taken outside of continental North America are considered to be unreasonable to the extent that they exceed what they would have been in connection with equivalent training in North America, if available. ...

Costs incurred in connection with attending a convention or a business meeting can receive different tax treatment from the costs of attending a training course. ... However, expenses incurred in connection with a full-time course of longer duration may, in certain circumstances, be considered reasonable. ... Claims in connection with training taken outside of continental North America are considered to be unreasonable to the extent that they exceed what they would have been in connection with equivalent training in North America, if available. ...

Accordingly, CRA is clarifying that where the employer's insolvency arose prior to 2012, the payment eventually made to the retirees in connection with the termination of the PHSP would not be subject to the revised position on taxability even if it is made in 2012 or later. 3. ... Provided the amount is paid prior to 2012, or is paid at any time in connection with the termination of coverage provided by an employer whose insolvency arose before 2012, the payer of the amount need not report the payment on an information return. ... Where such an amount is received prior to 2012, or at any later time in connection with the termination of coverage provided by an employer whose insolvency arose before 2012, it need not be reported by the recipient on his or her T1 General Income Tax and Benefit Return. ...