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Subsequently, on October 25, 2017 the Department of Finance released revised legislative proposals, followed on October 27 by Bill C-63 (“Bill C-63”), which expanded the scope of the tax-deferral mechanism of subsections 87(8.4) and (8.5) to also include joint elections made in connection with dispositions of certain taxable Canadian property (that is not treaty-protected property) that are interests in partnerships and interests in trusts. ... Pursuant to the October 25, 2017 draft proposals and Bill C-63, the above response would also apply for section 116 purposes in connection with valid joint elections that are filed in connection with partnership and trust interests. ... The Criminal Code also requires medical doctors and nurse practitioners providing medical assistance in dying to comply with the information filing requirements as regulated by the respective Ministry of Health in their jurisdiction, with similar filing requirements for pharmacists who dispense a substance in connection with the provision of medical assistance in dying. ...

When applied to ss. 7 and 247(2), this passage indicates that there is no direct connection – whether the amount is deductible is one matter, and the role the stock-based compensation plays in the application of s. 247(2), is a separate matter. ... The loan is incurred in connection with US LLC 2’s real estate operations in Canada, which constitutes its permanent establishment in Canada. ...

It really put blood into the veins of the connections between the authorities, and I think our day-to-day dynamic has improved. ...

CRA preliminary response The short-cut method (or direct assessment method) is an administrative measure adopted by the CRA to permit direct assessments of the shareholders of a corporation who were paid an excess amount in connection with an election under subsection 83(2). ... A, in connection with the estate freeze carried out by Mr. A. in favour of Initial Trust, if the Purpose Test were satisfied. ... Thus, subsection 74.4(2) could apply to the transfer of property made by Initial Trust, in connection with the estate freeze made by it in favour of New Trust, if the Purpose Test was satisfied. ...

Preliminary response B A strong connection between the Gagliese Productions case and a mortgage-lending business is not apparent. It is also unclear what the connection is between the mortgage-lending business and the rentals. ... It serves to report information about the trust itself, but also information that affects the taxation of persons who happen to have some connection to the trust – beneficiaries, settlors, and contributors. ...

It is anticipated that it will be required to be attached to one of the existing forms that are already required to be completed in connection with an FTS offering, such as the T100A. ... In many cases, this equipment is housed and operated in large datacenters capable of providing significant electricity and internet connections required for their use. ... Although crypto-asset mining equipment can connect directly to a blockchain network through an internet connection, most will prefer to connect to “mining pool” servers to increase their likelihood of receiving rewards. ...

Filings to amend the tax position of the trust and the beneficiary are as follows: • The trust would file Form T3A "Request for a Loss Carryback by a Trust" in connection with the loss year to request the loss be carried back to the prior year. • The trust would file Form T3-ADJ "T3 Adjustment Request" for the prior year to reflect a late subsection 104(13.1) or (13.2) designation so as to amend the trust's T3 Return. • The trust would issue amended T3 slips to the beneficiary for that prior year, reducing the income allocated. • The beneficiaries would file a Form T1-ADJ "T1 Adjustment Request" to reflect the revised T3 slip and to amend the T1 Return. ... A T3 return serves to report not only information about the reporting trust, but also additional information, such as that affecting the taxation of persons (for example, beneficiaries or settlors) having some connection to the trust. ...