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30 August 1990 Ruling 900443 F- Deductibility of Utility Service Connection Cost Unedited CRA Tags 20(1)(ee)   August 30, 1990 Current Amendments and Head Office Regulations Division Rulings Directorate B. ... Fontaine Acting Director 957-2095   900443   EACC9225 Paragraph 20(1)(ee) of the Income Tax Act (the "Act") Further to our recent telephone conversation with Don Joy, we request your comments as to whether a utility service connection cost incurred in the circumstances described below should, in terms of fiscal policy, be deductible even though the payment was made to a person other than the person who supplied the service.  ...

25 August 1989 Ruling 58483 F- Annuities Issued in Connection to Segregated Funds Unedited CRA Tags 146(1) qualified investment 19(1) File No. 5-8483   Maureen Shea-DesRosierss   (613) 957-8953 August 25, 1989 Dear Sirs: This is in reply to your letter of August 10, 1989 concerning annuities issued by 24(10 in connection with its segregated funds. ...

To the best of your knowledge and that of the taxpayer or a related person involved, none of the issues involved with this request: (i) is being considered by a tax services office or a taxation centre in connection with a tax return already filed by the taxpayer or a related person; (ii) is under objection; or (iii) is before the courts or, if a judgement has been issued, the time limit for appeal has not expired. ... Rulings Previously Issued by CRA in connection with Gco Project 19. Zco received the Tax Rulings XXXXXXXXXX. ... Subsections 17(1) and 17(2) will not apply to Zco to impute an income inclusion in connection with the New G Act Loan made by US LLC to G.I.E. ...

We also acknowledge the information provided in your letters and e-mails of XXXXXXXXXX, and during our various telephone conversations in connection with your ruling request (XXXXXXXXXX). ... Summary of the Transactions Undertaken in Connection with the Acquisition of Target By way of background, the sequence of transactions leading to the acquisition of Target by Bidco and the Target Winding-up can generally be summarized as follows: A. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

You have advised that to the best of your knowledge, and that of the responsible officers of each of the taxpayers, none of the issues involved in this Ruling is: (i) in an earlier return of any of the taxpayers or a related person; (ii) being considered by a tax services office (TSO) or taxation centre (TC) in connection with a previously filed tax return of any of the taxpayers or a related person; (iii) under objection by any of the taxpayers or a related person; (iv) before the courts or if a judgment has been issued the time limit for appeal to a higher court has expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... In connection with the DC Sub Share Exchange: (a) for the purposes of the BCA, the addition to the stated capital (and paid-up capital) of the DC Sub New Common Shares will be $XXXXXXXXXX and the addition to the stated capital (and paid-up capital) of the DC Sub Class C Shares will be $XXXXXXXXXX. ... In connection with the DC Share Exchange: (a) for the purpose of the BCA, the aggregate of the additions to the stated capital accounts of the DC New Common Shares and the DC Class C Shares will not exceed the paid-up capital of the DC Common Shares immediately prior to the DC Share Exchange. ...

They import such meanings 'in relation to', 'with reference to' or 'in connection with'.  The phrase 'in respect of' is probably the widest of any expression intended to convey some connection between two related subject matters. ... There is no requirement that the revenue guarantee have any connection with either the production of the video or the ownership of the video.   ...

This reduced standby charge is applicable provided the employee is required by the employer to use the automobile in connection with, or in the course of, the office or employment, and "all or substantially all" of the distance travelled by the automobile during the days in the year that it is available to the employee is in connection with, or in the course of, the office or employment. The Department considers the phrase "all or substantially all" to mean at least 90% of the distance travelled being in connection with, or in the course of, the office or employment. ...

Provided the Lender is the employer and the employee is not a "specified employee" as defined in subsection 248(1), by virtue of subsection 15(2.4), the provisions of subsection 15(2) will not apply to an employee who is a shareholder of Canco or any of its affiliates in respect of Loans or Interest Loans received by the employee from the Lender in connection with their investment XXXXXXXXXX. ... By virtue of the provisions of section 80.5, paragraph 20(1)(c) will apply to permit an employee a deduction in a taxation year equal to the amount of the inclusion in income under subsection 80.4(1) for the year in respect of Loans and Interest Loans received in connection with their investment XXXXXXXXXX, to the extent that the borrowed funds continue to be used for the purpose of gaining or producing income. ... Apart from the application of subsection 6(9) as set out in Ruling C, the provisions of section 6 will not apply to include an amount in the income of an employee solely as a result of XXXXXXXXXX, the acquisition by an employee of XXXXXXXXXX or the receipt of the Loans or the Interest Loans by the employee in connection with their investment XXXXXXXXXX. ...

.; (b) "Client" means the XXXXXXXXXX; (c) "Contract" means the XXXXXXXXXX-year lease contract for the Product as described in paragraph 3 below; (d) "Country 1" means XXXXXXXXXX; (e) "Country 2" means XXXXXXXXXX; (f) "CRA" means the Canada Revenue Agency; (g) "Overseas Employees" means the employees of Aco who will perform their employment duties in Country 1 in connection with the Contract; (h) "OETC" means the overseas employment tax credit in section 122.3 of the Act; (i) "Product" means the XXXXXXXXXX; (j) "Subcontractor" means XXXXXXXXXX; and (k) "Subcontractor Supervisor" means the employee of Aco who will carry out certain activities in Country 2 in connection with the Contract. ... In connection with its obligations under the Contract, Aco will send an XXXXXXXXXX ("Subcontractor Supervisor") to Country 2 for a continuous period of XXXXXXXXXX to supervise the Subcontractor. ... The activities described in 9(a) to 9(d) and 13(a) to 13(e) above will represent more than 50% of all activities that will be undertaken by Aco in Country 1 and Country 2 in connection with the Contract. 16. ...

In paragraph 27, line 12, following the last sentence of the first subparagraph, add the following sentence: "XXXXXXXXXX has incurred financing expenses of approximately $XXXXXXXXXX in connection with this refinancing which are deductible under paragraph 20(1)(e). ... As consideration for assuming the debt of XXXXXXXXXX referred to in paragraph 27 above, XXXXXXXXXX will reimburse XXXXXXXXXX Amalco for the financing expenses incurred by XXXXXXXXXX in connection with this debt by issuing and delivering to XXXXXXXXXX Amalco a non-interest-bearing demand promissory note (the "XXXXXXXXXX Reimbursement Note" and the "XXXXXXXXXX Reimbursement Note", respectively), the principal amount of which will be equal to one-half of such financing expenses. ... XXXXXXXXXX will each be entitled to deduct in accordance with paragraph 20(1)(e) in computing its income for the taxation year in which payment is made to XXXXXXXXXX Amalco and following taxation years the amount paid by each of them to XXXXXXXXXX Amalco referred to paragraph 34A as reimbursement of financing expenses incurred by XXXXXXXXXX in connection with the refinancing referred in paragraph 27. ...