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Conference

24 February 1992 Roundtable, 9206080 F - 92 Manitoba CBA/CICA Roundtable

Manitoba Property Tax Credits Question 9 In connection with Manitoba property tax credits, there have been instances where clients have paid property taxes but have not received the homeowners assistance.  ...
Ruling

2021 Ruling 2021-0906111R3 - XXXXXXXXXX Post-mortem Pipeline

The tax account numbers, Tax Services Offices, and Tax Centres of the taxpayers involved are as follows: XXXXXXXXXX (collectively, the “Taxpayers”) We understand that to the best of your knowledge and that of the Taxpayers, none of the Proposed Transactions or issues involved in this Ruling are the same as or substantially similar to transactions or issues that are: a) in a previously filed tax return of the Taxpayers or a related person and: i. being considered by the CRA in connection with such return; ii. under objection by the Taxpayers or a related person; or iii. the subject of a current or completed court process involving the Taxpayers or a related person; or b) the subject of a ruling request previously considered by the Income Tax Rulings Directorate. ...
Technical Interpretation - Internal

21 September 2021 Internal T.I. 2019-0807491I7 - Subsections 93.1(5) and (6)

Any references or discussion in this document pertaining to the characterization of LLC2’s interest as FAPI or as ABI is in connection with the characterization of the income in respect of USP only. ...
Ruling

2022 Ruling 2021-0910431R3 - Loss consolidation arrangement

To the best of your knowledge and that of the taxpayers involved, none of the proposed transactions or issues involved in this Ruling request are the same as or substantially similar to transactions or issues that are: i. in a previously filed tax return of the taxpayers or a related person and: A. being considered by the CRA in connection with such return; B. under objection by the taxpayers or a related person; or C. the subject of a current or completed court process involving the taxpayers or a related person; or ii. the subject of a Ruling request previously considered by the Income Tax Rulings Directorate. ...
Ruling

2023 Ruling 2023-0961681R3 - CEE Incurred by a Non-resident

We understand that to the best of your knowledge and that of the Taxpayers, none of the proposed transactions and/or issues involved in this ruling request are the same as or substantially similar to transactions or issues that are: (a) in a previously filed tax return of the Taxpayers or a related person and; (i) being considered by the Canada Revenue Agency in connection with any such tax return; (ii) under objection by the Taxpayers or a related person; (iii) the subject of a current or completed court process involving the Taxpayers or a related person; or (b) the subject of a ruling request previously considered by the Income Tax Ruling Directorate in relation to the Taxpayers or a related person. ...
Ruling

2024 Ruling 2022-0948081R3 - Loss Consolidation Arrangement

To the best of your knowledge and that of the taxpayers involved, none of the proposed transactions or issues involved in this Ruling request are the same as or substantially similar to transactions or issues that are: i. in a previously filed tax return of the taxpayers or a related person and: A. being considered by the CRA in connection with such return; B. under objection by the taxpayers or a related person; or C. the subject of a current or completed court process involving the taxpayers or a related person; or ii. the subject of a Ruling request previously considered by the Income Tax Rulings Directorate. ...
Ruling

2008 Ruling 2007-0241221R3 - 55(3)(b) butterfly reorganization

No section 85 election will be filed in connection with such exchanges, the parties relying instead on section 51. 17. ... No section 85 election will be filed in connection with such exchanges, the parties relying instead on section 51. ... The amount shall be designated pursuant to the resolution of the directors of Subco A and Transferee Z, as the case may be, made in connection with the issuance of such share. ...
Archived CRA website

ARCHIVED - Expenditures on Research and for Business Expansion

In this latter case, architectural, engineering and other expenses relating to the proposed creation or acquisition of a specific capital asset are eligible capital expenditures (as defined in paragraph 14(5)(b)) for which an allowance is permitted by virtue of paragraph 20(1)(b) of the Act, provided that the expenses are incurred in connection with a business carried on by the taxpayer. ... Whether the asset is acquired or not, there may be some expenditures in connection therewith that are specifically deductible under the provisions of the Act. ...
Old website (cra-arc.gc.ca)

Chapter History - S4-F5-C1: Share for Share Exchange

However, these sections now appear in the Table of contents for easy access; the statement that folios are only available in electronic format has been moved to the end of the Application section; and the words “as promulgated under the Act” in connection with the Income Tax Regulations have been removed from the Application section, in the interest of using plain language. The following specific changes have been made to this Chapter: ¶1.6(f) has been revised to include a reference to paragraph 85.1(2)(c). ¶1.11 has been revised to remove the word “reporting” in connection with the section 116 requirements to better reflect the legislation. ¶1.4, 1.11, 1.14 and 1.15 of the French Chapter only have been revised to improve readability. ...
Scraped CRA Website

ARCHIVED - Expenditures on Research and for Business Expansion

In this latter case, architectural, engineering and other expenses relating to the proposed creation or acquisition of a specific capital asset are eligible capital expenditures (as defined in paragraph 14(5)(b)) for which an allowance is permitted by virtue of paragraph 20(1)(b) of the Act, provided that the expenses are incurred in connection with a business carried on by the taxpayer. ... Whether the asset is acquired or not, there may be some expenditures in connection therewith that are specifically deductible under the provisions of the Act. ...

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