Search - connection

Income Tax Convention (1980) (the "1980 Convention") would apply to interest paid with respect to a debt obligation guaranteed by the Eximbank in connection with financing of the purchase of XXXXXXXXXX In this regard, you referred to a letter issued by XXXXXXXXXX, dated January 24, 1984, (the "January 24, 1984 letter") which you stated did not consider the possible application of Article XI of the 1980 Convention. ...

Our Comments For the purposes of our reply we have assumed the following: 1. the intermediary and final user are resident in Canada; 2. the intermediary does not have in Argentina, a permanent establishment or a fixed base in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment or fixed base; 3. the indebtedness in respect of which the interest is paid arose as a consequence of the sale on credit by a resident of Argentina of the machinery or equipment; and 4. the intermediary and the final user are not related to the recipient of the interest. ...

Page 16 of this guide indicates that reimbursements of directors' expenses in connection with out-of-town accommodation and travel expenses while attending a board meeting will not be considered taxable employment benefits. ...

It is our understanding that Department of Finance is continually reviewing the legislation governing medical expenses to ensure that all proper costs incurred in connection with a medical disability are properly recognized for tax purposes. ...

The shareholders of Targetco (which include one or more residents of Canada) receive shares of Mergeco and Acquisitionco according to exchange ratios established in connection with the Merger. ...

CCRA officials were also asked to clarify some of the various income tax rules that may apply to transactions in connection with a woodlot, so that interested parties could seek legislative change to obtain the desired results. ...

Under paragraph 146.3(2)(d) of the Income Tax Act (the "Act"), a RRIF will not be accepted for registration unless the terms of the RRIF provide that, except where the annuitant's spouse becomes the annuitant under the RRIF contract, the RRIF distributes the property held in connection with the RRIF at the time of the annuitant's death. ...

Costs may also include registration fees and payment to an Internet provider who will furnish an Internet address and connections to various search engines. ...

Costs may also include registration fees and payment to an Internet provider who will furnish an Internet address and connections to various search engines. ...

The employee assistance program you are concerned with could include: stress management, dealing with addictions and habits, conflict management and resolution, healthy life-style development, health hazards in the workplace and at home, and understanding the mind-body connection for good health. ...