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In general terms, the provisions of the Income Tax Act (the “Act”) pertaining to RCAs apply to any arrangement whether contractual or otherwise where contributions are made by an employer, a former employer or a person who is not at arms length with the employer to a custodian in connection with benefits that are to be paid to a former employee on retirement or loss of employment except in specific excluded situations. ...

The Canadian and British Insurance Companies Act ("CABICA") defines the "business of insurance" to mean "the making of any contract of insurance, and includes any act or acts of inducement to enter into such a contract, and any act or acts relating to the performance thereof, or the rendering of any service in connection therewith". ...

For example, subparagraph 184(1)(b)(iii) of the Canada Business Corporations Act ("CBCA") states that on a vertical short-form amalgamation "no securities shall be issued by the amalgamated corporation in connection with the amalgamation". ...

7 May 1991 Income Tax Severed Letter- Price adjustment clause Unedited CRA Tags 85, 86 Edmonton District Office Annual Tax Group Meeting Q. 17 Price Adjustment Clauses Price adjustment clauses are commonly used in connection with shares issued in the context of section 85 rollovers and section 86 reorganizations. ...

In connection with this point, we offer the following comments concerning payments for computer software programs which may help to explain the exemption provided under subparagraph 212(1)(d)(vi) of the Act. ...

.), the phrase "in respect of" has been given the widest possible scope to convey some connection between two related subject matters. ...

We do not have sufficient information concerning the staff retirement funds or the circumstances under consideration by you in connection therewith to comment definitively as to the proper tax treatment thereof. ...

16 September 1981 Income Tax Severed Letter RRRR43- Foreign affiliates Unedited CRA Tags 95(2)(a), Reg. 5907 Dear Sirs: This is in reply to your letter of January 26, 1981 in connection with the above. ...

. • There can be no direct connection between the amount of the individual's contribution and disbursement from the fund or allocations of equipment to that person, nor should there be any option to purchase equipment acquired with the funds at the end of a certain time period. ...

Subsection 67.1(1) of the Act contains the words "in respect of" which we interpret to mean in relation to or in connection with. ...