Search - connection
Results 1331 - 1340 of 15551 for connection
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S1-F2-C1 - Qualifying Student and the Education and Textbook Tax Credits
As described in ¶1.20, receipt of a benefit frequently disqualifies a student from being entitled to an education tax credit, or being a qualifying student, in connection with a program as the student is not enrolled in a qualifying educational program. ... Income from employment 1.29 For tax years prior to 2004, a program was excluded from the definition of a qualifying educational program if the program was taken by a student during a period in which the student received income from an office or employment and the program was in connection with or as part of the duties of that office or employment. ...
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S2-F1-C3 - Pension Benefits
In addition, the plan is subject to the special refundable tax regime described in Part XI.3. 3.33 Generally, an RCA is an arrangement under which an employer makes contributions to a third-party custodian in connection with benefits that are payable to employees after retirement or termination of employment. ... However, if a foreign plan otherwise meets the RCA definition and employer contributions have been made in connection with services rendered by Canadian‑resident employees and certain other conditions are met, the RCA residents’ arrangement rules in subsections 207.6(5) and (5.1) may apply to treat the Canadian portion of the plan as an RCA. ...
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S2-F2-C1 - Employee Professional Membership and Other Dues
However, there must be a reasonable connection between the professional membership and the position or job held by the employee. ...
Article Summary
Jason Boland, Christopher Montes, "A Detailed Review of the Back-to-Back Loan Rules", 2016 Conference Report (Canadian Tax Foundation), 26:1-32 -- summary under Subparagraph 18(6)(c)(i)
Jason Boland, Christopher Montes, "A Detailed Review of the Back-to-Back Loan Rules", 2016 Conference Report (Canadian Tax Foundation), 26:1-32-- summary under Subparagraph 18(6)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(6)- Paragraph 18(6)(c)- Subparagraph 18(6)(c)(i) Meaning of “because of” in s. 18(6)(c)(i) (p. 26:8) While the Supreme Court's comments in Copthorne appear to soften the "strong causal connection" language from Krull [a.k.a. Hoefele] both cases suggest that there needs to be some level of connection.... ...
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S1-F1-C1 - Medical Expense Tax Credit
Some of the main exceptions are: paragraph 118.2(2)(b.1) in respect of attendant care provides that the attendant care must be provided in Canada; paragraph 118.2(2)(b.2) in respect of care in a group home provides that the group home must be located in Canada; paragraph 5700(w) of the Regulations, dealing with talking textbooks for use by a patient with a perceptual disability in connection with the patient’s enrolment at an educational institution, requires that the educational institution either be in Canada, or be a designated educational institution (as defined in section 118.6 – see Income Tax Folio S1-F2-C1, Qualifying Student and the Education and Textbook Tax Credits). 1.13 As noted at ¶ 1.4, an otherwise eligible medical expense in respect of a dependant who is the parent, grandparent, brother, sister, uncle, aunt, niece or nephew of the individual, or of the individual’s spouse or common-law partner, may only be claimed where that dependant is a resident of Canada at some time in the year in which the expense was incurred. ... The talking textbook must be for use in connection with that patient’s enrolment at an educational institution in Canada or a designated educational institution. ... Receipts are not required for meal and vehicle expenses claimed as transportation and travel expenses under paragraph 118.2(2)(g) and (h), or in connection with bone marrow or organ transplants under paragraph 118.2(2)(l.1) where the simplified method of calculating meal and vehicle expenses is chosen. 1.147.1 Where an individual chooses to claim the limited amount of attendant care expenses provided under paragraph 118.2(2)(b.1) plus the disability tax credit (see ¶1.35) in respect of an eligible person with a disability who receives full-time care in a nursing home, a breakdown of the amounts charged by the nursing home showing the portion for attendant care would be required in order to make a claim under paragraph 118.2(2)(b.1). ...
Article Summary
Shane Onufrechuk, Warren Pashkowick, "Tax Considerations of Major Construction Projects", 2014 Conference Report, Canadian Tax Foundation, 10:1-35. -- summary under Paragraph 18(6)(c)
.-- summary under Paragraph 18(6)(c) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(6)- Paragraph 18(6)(c) Simplified overview of rule (p. 10:13) A back-to-back loan exists when a Canadian resident has an outstanding interest-bearing debt obligation (Canadian debt) to an arm's-length lender (intermediary) if there is a debt owing by the intermediary (or a person who does not deal at arm's length with the intermediary) to a person who does not deal at arm's length with the Canadian resident (intermediary debt), and when any one of the following three conditions are met: 1) recourse of the intermediary debt is limited to the Canadian debt; 2) a strong causal connection exists between the intermediary debt and the Canadian debt; or 3) the intermediary (or a person that does not deal at arm's length with the intermediary) has a "specified right" granted by a non-resident connected to the Canadian resident, and a strong causal connection exists between the specified right and the Canadian debt. ...
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Jeffrey T. Love, Kenneth R. Hauser, "How Various Aggregation Rules Apply to Trusts", 2018 Conference Report (Canadian Tax Foundation), 28: 1-79 -- summary under Majority-interest group of beneficiaries
Hauser, "How Various Aggregation Rules Apply to Trusts", 2018 Conference Report (Canadian Tax Foundation), 28: 1-79-- summary under Majority-interest group of beneficiaries Summary Under Tax Topics- Income Tax Act- Section 251.1- Subsection 251.1(3)- Majority-interest group of beneficiaries Determination of whether beneficiaries constitute a “group” (pp. 28:33-34) We suggest that the above case-law principles should be applied to determining whether beneficiaries of a trust constitute a group of persons in the following manner: 1) There must be sufficient common connection between the beneficiaries in addition to their being beneficiaries of the same trust. A common identifying feature (such as being non-residents, as in Silicon Graphics) is insufficient to establish such a connection. 2) The common connection might include but is not limited to a voting agreement, an agreement to act in concert, or a business or family relationship. 3) Beneficiaries may share a mutually beneficial objective, such as maximizing the value of their investments in the trust, without being considered a group. 4) Beneficiaries can participate in modern corporate or commercial steps, such as granting a proxy or participating in a reorganization of the trust (for example, a fund merger pursuant to section 132.2), without being considered a group. 5) Whether the beneficiaries know, can identify, or communicate with each other is relevant in determining whether they are a group. ...
Article Summary
Ian Bradley, Denny Kwan, Dian Wang, "Is The Back-to-Back Withholding Tax Regime an Effective Anti-Treaty-shopping Measure?", Canadian Tax Journal, (2016) 64:4, 833-58 -- summary under Subsection 212(3.1)
This could make it more difficult to establish the requisite connection between equity investments (although the back-to-back rules do address some connections involving equity investments—for example, in the character substitution rules)…. ...
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Joint Committee, "August 9, 2022 Technical Amendments - Application of Part XIII tax where payer or payee is a partnership", 22 March 2023 Joint Committee Submission -- summary under Paragraph 212(13.1)(a)
Such concerns would arise for instance regarding a foreign partnership whose only connection to Canada is the residence of some partners who might be passive and constitute a very small minority of the partners. Quaere, how CRA could enforce the rule if the only Canadian connection was Canadian resident passive investors. ...
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S1-F3-C1 - Child Care Expense Deduction
Subsection 251(6) defines a connection by blood relationship, marriage, common-law partnership or adoption for the purposes of the Act. ...