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In particular, paragraph 3 provides that treaty benefits may be available to a US resident with respect to income derived from Canada, provided that the income is derived in connection with, or is incidental to, the active conduct of a trade or business (other than certain investment businesses) carried on in the US by the US resident, or a person related to the US resident, and provided that the US trade or business is substantial in relation to the activity carried on in Canada giving rise to the income. ...

Subsequently, on October 25, 2017 the Department of Finance released revised legislative proposals, followed on October 27 by 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. ...

S. 95(3)(b) concerns services performed in connection with the purchase or the sale of “goods.” ...

In this regard, the Act does not specify whether the "FMV of any consideration … received by the donee for the disposition” of the NQS refers to the specific concept of "proceeds of disposition" provided for in s. 54 or, more generally, to any consideration received in connection with such disposition, including the portion of such consideration that would constitute a deemed dividend under s. 84(3), in the event of a redemption of shares. ... Official Response 7 October 2021 APFF Roundtable Q. 18, 2021-0901091C6- TOSI continuity rule for inherited property Q.19 Ruling service fee remissions The service fees charged by CRA in connection with an advance (including supplementary) income tax ruling (an "Advance Income Tax Ruling") as well as a pre-advance ruling consultation ("Pre-advance Consultation") are governed by the Service Fees Act, s. 7 of which provides for an obligation to refund a portion of the service fees charged ("Remission") when a performance standard is not met a) How will this be done? ...

Darren Weiner provided a verbal update (b) Carbon fuel charge audits Please provide an update regarding CRA audits in connection with the fuel charge under Part 1 of the Greenhouse Gas Pollution Pricing Act. ... Are rapid COVID tests performed by someone who is not a medical practitioner/nurse/pharmacist (e.g., a travel agency without a connection to a medical practitioner, nurse or pharmacist) taxable? ...

Question 14: Availability of Small Business Deduction Corporation A is a Canadian controlled private corporation that carries on active business in Canada, and holds property in connection therewith. ... Ronald Robertson and Roger Saunders, 2012 FCA 94.] have also stated that connections that are artificial should not be given weight in determining if income is situated on a reserve for purposes of the exemption. ...

We understand that it can be argued that this shift of an amount from the ERDTOH account to the NERDTOH account results from the fact that paragraph 186(1)(b) makes no connection between the type of RDTOH account entitling Aco to the DR and the type of dividend received by Bco and Cco. ... The courts have generally recognized that, in order to conclude that several persons collectively exercise control of a corporation, there must be a sufficient connection between those persons, such as a voting rights agreement, an agreement to act in concert or business or family ties. ...

What actions did the taxpayer take in connection with the reduction in value?” ...

This provision applies where there has been an increase in the total fair market value of the property held in connection with a registered plan that can reasonably be considered to be attributable, directly or indirectly, to a transaction or event (or series) if two conditions are met: the transaction or event would not have occurred in a normal commercial or investment context in which parties deal with each other at arm's length and act prudently, willingly and knowledgeably; and one of the main purposes of the transaction or event is to benefit from the plan’s taxexempt status. ...