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In connection with this business, the BD Partnership pays royalties to Corporation X and Corporation X, in turn, pays royalties (in equal amounts) to Corporations A and C. ...

Co. in connection with any business carried on by it in Canada. 3. The loan is not repaid by the end of Year 2 with the result that subsection 15(2) and paragraph 214(3)(a) apply to deem the amount of the loan to be a dividend paid by Canco to U.K. ...

7 October 1990 Income Tax Severed Letter- Non-profit Organizations Unedited CRA Tags 149(5) XXX Re: Non-Profit Organizations This is in reply to your letter of October 15, 1990 and further to our telephone conversations of October 17 and 19, 1990 requesting a written interpretation of certain facts in connection with a non-profit sporting or recreational organization (the "NPO") of which you are a member. ...

7 February 1991 Income Tax Severed Letter- Assignment of Liability- Structured Settlements Unedited CRA Tags IT-365R2 Re: Assignment of Liability-Structured Settlements This is in reply to your letter of January 4, 1991 requesting a technical interpretation in connection with the assignment of liability in relation to a structured settlement for damages arising from a personal injury or death claim by an individual. ...

Subsection 1892) of the Act generally operates to disallow the deduction of interest and property taxes, being referred to herein as carrying charges, in connection with the acquisition of land except to the extent, inter alia, of net incidental income earned therefrom. ...

TAX STUDY GROUPS ROUND TABLE Q.15 Price Adjustment Clauses Price adjustment clauses are commonly used in connection with shares issued in the context of section 85 rollovers. ...

Against the Offshore Business income, the Individual claims capital cost allowance (“CCA”) on a building, located offshore, (the “Offshore Building”) owned by the Individual and used in connection with the Offshore Business. 4. ...

As previously noted XXX In this connection, we have enclosed a copy of Interpretation Bulletin IT-73R4 which discusses the Department's view with respect to an active and a specified investment business. ...

In this connection the Webster's Ninth New Collegiate Dictionary has the following meaning for the word "transfer": "to convey from one person, place, or situation to another". ...

A RCA is defined in subsection 248(1) of the Income Tax Act ("Act") basically as an arrangement under which payments are made by an employer to a custodian in connection with benefits that are to be received on retirement. ...