Search - connection

The lessor has no other relevant connection to Canada, e.g., agents, employees or facilities in Canada, soliciting of Canadian business, Canadian bank accounts or servicing obligations under the lease. ...

A shareholder who receives property from a corporation in connection with the repurchase of the shareholder’s shares by the corporation disposes of those shares to the corporation in exchange for the property the shareholder receives. ...

Regarding GAAR, CRA would look for a sufficient connection between the deceased person and the property that is being distributed, and the specified individual, to justify or support the application of the deeming rule in these circumstances. ...

This policy was assigned as security at the request of the lender (by way of a movable hypothec) in connection with a loan taken out to earn income from a business or property. a) Does the CRA agree with the conclusion set out in Interpretation Letter 19-045061-001 [FN18: REVENU QUÉBEC, Interpretation Letter 19-045061-001, "Calculation of Business Income- Deduction of Critical Illness Insurance Premiums- Assignment of Policy as Security- Commercial Loan", January 28, 2020.] rendered on January 28, 2020 by the Agence du revenu du Québec, which recognized that a taxpayer, in computing business or property income could deduct, as a guarantee expense, the premiums on a CII policy contracted and assigned to the lender at the latter's request, pursuant to s. 176.4 of the Taxation Act [FN19: RLRQ, c. ...

Official Response 3 December 2024 CTF Roundtable Q. 13, 2024-1038261C6- Standard Convertible Debentures and Part XIII Tax Q.14- Scope of active business income Corporation A is a Canadian controlled private corporation that carries on active business in Canada, and holds property in connection therewith. ...

S.141.1(3) deems anything done by a person in connection with the acquisition or establishment of a commercial activity of the person to be done in the course of the commercial activities of the person. ... To the extent that the adoption of a pre-incorporation contract is in connection with acquiring or establishing the commercial activities of a newly formed corporation, paragraph 141.1(3)(a) of the ETA will deem the adoption of that contract to be done in the course of the corporation’s commercial activities. ...

In connection with those risk assessments, the CRA held more than 175 face-to-face meetings with officials from large businesses. ...

Preliminary CRA written response to Q.8(a) Paragraph 8(1)(f) provides that a taxpayer who was employed in the year in connection with the selling of property or negotiating of contracts for the taxpayer’s employer, may deduct in computing the taxpayer’s income amounts expended by the taxpayer in the year for the purpose of earning income from the employment subject to certain conditions provided for in that paragraph. ...

As indicated in B-103, to be considered a service in relation to a location-specific event for purposes of section 28 of the Regulations, there must be a direct connection between the service and the event. ...

The T3 return serves to report information about the trust itself along with information that affects the taxation of persons who have some connection to the trust. ...