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7 November 1990 Ministerial Letter 903108 F- Deductibility of Costs Incurred in Connection with a Takeover Bid Unedited CRA Tags n/a   November 7, 1990 R.K. ... Harms   (613) 957-2109   903108 SUBJECT:  Deductibility of costs incurred in connection with a takeover bid On November 2, 1990, Mr. ...

Reasons: Considered incidental, connection insufficient. December 8, 1998 Client Services Directorate HEADQUARTERS Ministerial Correspondence Division D. ... Where less than 90% of the duties are performed on a reserve the exemption can be prorated, however, there still must be a sufficient connection to consider that part of the employment is situated on the reserve. ... Where the time on the reserve consists of irregular intervals of short amounts of time, we would likely consider the connection to be incidental and, therefore, the income would be fully taxable. ...

A building must be used in connection with the earning of business income or property income in order for mortgage interest expenditures to be deductible.  If the building is not being used for income-earning purposes, as in the case of a personal residence for example, then expenditures incurred in connection with the property would not be deductible. ...

You further enquire as to whether an employee covered by an individual RPP could deduct any expenses paid by him in connection with establishing the RPP. ... In our opinion, an employee is not entitled to deduct expenses paid in connection with establishing an individual RPP since these expenses belong to the employer or the trustee of the RPP. ...

This value is an amount equal to a prescribed amount per kilometre for operating costs in connection with personal use and a reasonable standby charge, plus the equivalent to the Goods and Services Tax on the standby charge. ... The standby charge may be reduced when the personal use is less than 1,000 kilometres a month and at least 90 per cent of the distance travelled by the automobile in the total days available is in connection with, or in the course of, the office or employment. Further, provided the automobile is used primarily in connection with, or in the course of, the office or employment, an amount equal to one-half of the standby charge benefit may be used as the amount of the operating costs benefit in lieu of the per kilometre calculation. ...

Only "qualified activities" may be considered in the calculation of a corporation's M & P profit and section 5202 of the Regulations provides an exhaustive definition thereof which may be paraphrased as follows: "qualified activities" means (a)      any of the following activities... in connection with manufacturing or processing... ... (b)      all other activities... directly in connection with manufacturing or processing... but does not include any of (d)      ... shipping... of finished goods, (e)      purchasing of raw materials... ... " XXX The phrase "directly in connection with" as used in paragraph (b) of the definition "qualified activities" must be fulfilled in order for the transportation to be a "qualified activity". ...

" In the light of this definition, the handling of woodchips to be shipped to the pulpmill may be a qualified activity in connection with manufacturing or processing under the definition of "qualified activities" found at section 5202(a)(iii) of the Regulations, but certainly not the shipping itself (i.e. the transportation).  ... It is further contended that the transportation of woodchips is not "directly in connection with manufacturing or processing".  The phrase "directly in connection with" as used in paragraph (b) of the definition "qualified activities" must be fulfilled in order for the transportation to be a "qualified activity".  ...

Reasons FOR POSITION TAKEN: Old Age Security income does not have any reserve connection and is taxable. ... However, old age security income does not have any reserve connection and remains taxable. ...

It should be noted that Canada has no authority in connection with the administration and enforcement of the United States estate tax and that our opinion in connection therewith would not be binding on the United States. ...

Principal Issues: whether medical residents at a teaching hospital would be entitled to a tuition and education tax credit if they are charged a tuition fee for the period of their residency Position: tuition tax credit would likely be available but education tax credit would not Reasons: residents receive employment income in connection with their residency A. ... This definition specifically excludes a program of study which is taken in connection with or as part of the duties of the student's employment and the student is receiving compensation for that employment. ...