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Experts corner Debts incurred by charitable foundations Debts incurred for the purpose of acquiring investments will now be viewed as a "debt incurred in connection with the purchase and sale of investments" for purposes of paragraphs 149.1(3)(d) and (4)(d). It had been our view that the phrase "debts incurred in connection with the purchase and sale of investments" should be interpreted fairly strictly. ... The phrase “in connection with” has a very broad meaning. The CRA’s revised position is consistent with the policy intent of subparagraph 3702(1)(b)(iii) of the Income Tax Regulations. ...

Response 3 Yes, a significant issue has been considered over the last few months in connection with the funding of the cost of long-term disability benefits under "group sickness and accident plans" that are administered by employers through a health and welfare trust. ... The Tax Court of Canada concluded that the non-resident shareholders had de jure control of Alias because they held the simple majority of voting shares, notwithstanding that there was no common connection between them. ... As there was no evidence of a common connection, the Federal Court of Appeal overturned the Tax Court of Canada's decision. ...

Response 3 Yes, a significant issue has been considered over the last few months in connection with the funding of the cost of long-term disability benefits under "group sickness and accident plans" that are administered by employers through a health and welfare trust. ... The Tax Court of Canada concluded that the non-resident shareholders had de jure control of Alias because they held the simple majority of voting shares, notwithstanding that there was no common connection between them. ... As there was no evidence of a common connection, the Federal Court of Appeal overturned the Tax Court of Canada's decision. ...

In this connection it is important to note that in computing the income of a partnership, subsection 96(1) and Regulations 1102(1a) require that partnership property (including depreciable property) be accounted for as if it were owned at the partnership level. 3. ...

For example, a gain realized on the sale of vacant land acquired in connection with a planned extension of club facilities that has since been abandoned is taxable in the hands of the deemed trust regardless of the reason for the change in plans or the fact that the land was not used for any purpose whatever during the period that it was held. ...

The term "permanent establishment" is defined in subsection 400(2) of the Regulations in connection with the determination of "taxable income earned in the year in a province" (as defined in subsection 124(4)) for purposes of the deduction under subsection 124(1). ...

Where different parts of the class were used in connection with different timber limits or sections thereof, separate rates are computed for each part of the class as though each part of the class were the taxpayer's only property of that class. ...

The following properties are not included in class 22 or 38, even though they may fit the description of qualifying equipment: (a) Vessels (including dredges), equipment forming part of a marine railway, and any other property included in class 7, (b) Property forming part of a railway, included in class 4, (c) Logging equipment included in class 10 by virtue of paragraphs (n) or (o) of that class, (d) Mining equipment and other property used in connection with a mine included in class 28 or 41 or in class 10 by virtue of paragraphs (k),(l), (m) or (r) of that class. ...

Where the owner and tenant were not dealing at arm's length, such a payment made in connection with a disposition, or a deemed disposition under subsection 45(1), of the property was considered to be an outlay or expense made or incurred for the purpose of making the disposition or deemed disposition and entered into the calculation of the capital gain or loss under subsection 40(1), provided the payment was reasonable in the circumstances. 12. ...

Under this Act, members of the armed forces of a designated state and civilian personnel designated as a civilian component of such forces, who are present in Canada in connection with official duties, are exempt from taxation in Canada on the salary and emoluments paid to them in such capacity. ...