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However, all contributions to the plan after December 31, 1987 and all property that can reasonably be considered to derive from those contributions at deemed to be property held in connection with the statutory plan, which property is subject to the RCA rules.  ...

The comments in this letter are of general nature only and do not take into account considerations that might arise in connection with a specific transaction or event.  ...

" The court also held at page 1142 that:      "Having regard to the business carried on by a non-resident insurer, that is, the business of insurance, the definition of "Canadian reserve liabilities" is broad enough to include the liabilities and reserves reported to the relevant authority under the relevant provisions of the Insurance Act which have a connection, directly or indirectly, with the insurer's insurance policies in Canada. ...

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.  ...

Our understanding of the facts of your situation are as follows: 24(1) 24(1) In connection with the questions you have asked, we wish to note that based on the above information provided to us, the Fund, in our view, is an "employee benefit plan" pursuant to the definition of this term in subsection 248(1) of the Income Tax Act (the Act).  ...

In our opinion, the interest paid by USCo to Canco on the loan made by Canco to USCo would be considered to be interest and taxable as such under the Income Tax Act and Canco would not be entitled to a deduction under section 113 of the Act in connection therewith, irrespective of whether such interest is re-characterized and deemed to be a dividend by and for the purposes of the United States Internal Revenue Code. ...

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". ...

Baumeister (613) 995-0051 January 18, 1982 Dear Sirs: This is in reply to your letter of December 8, 1981, in connection with the deductibility of certain fees paid by an annuitant to the trustee of his self-administered RRSP. ...

In this connection, you wish to know if a loss incurred in the following circumstances is a business investment loss pursuant to paragraph 39(1)(c) of the Income Tax Act (the "Act"): XXXX We confirm that after the divorce the taxpayer and his former wife are not related for purposes of the Act but wish to advise that paragraph 251(1)(b) of the Act states "it is a question of fact whether or not persons not related to each other were at a particular time dealing with each other at arm's length". ...

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. ...