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Ruling
19 May 1992 Ruling 9212813 F - Scholarship Fund
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). ...
Technical Interpretation - External
2 November 1990 External T.I. 901355 F - U.S. Internal Revenue Code Re Treatment of Certain Interests in Corporations as Stock or Indebtedness
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. ...
Technical Interpretation - External
9 December 1991 External T.I. 9122455 F - Vertical Short Form Amalgamation
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". ...
Miscellaneous severed letter
18 January 1982 Income Tax Severed Letter
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. ...
Miscellaneous severed letter
3 June 1981 Income Tax Severed Letter
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". ...
Miscellaneous severed letter
17 July 1991 Income Tax Severed Letter 5-911304 - [Application of Paragraph 67.1(2)(e)]
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. ...
Miscellaneous severed letter
23 November 1973 Income Tax Severed Letter
It would be appreciated if you could outline your position and interpretation concerning this matter so we may be in a position to reply to the many Canadian residents who are writing us asking for information in this connection. ...
Miscellaneous severed letter
20 November 1985 Income Tax Severed Letter B-6485 - [Bill C-72 Amendment to Paragraph 62(1)(g)]
The type of assistance provided is a lump sum allowance based on the distance to be travelled and is intended to provide for assistance to persons who are moved from one place in Canada to another place in Canada in connection with the Canada Mobility Program. ...
Miscellaneous severed letter
16 April 1981 Income Tax Severed Letter
In connection with the situation where goodwill is sold and there is uncertainty as to when an amount will be paid or there is to be a delay of several years in payment, it is our position that the proceeds of disposition as determined in the year of sale are considered to constitute an amount that "became payable" for the purposes of section 14 and that a reserve is not available with respect to anticipated future receipts or with respect to an allowance for doubtful amounts. ...
Miscellaneous severed letter
12 October 1983 Income Tax Severed Letter
It is our opinion that all of your officers engaged in obtaining documentation in connection with the class 34 certification process are subject to the provisions of subsection 241(1) of the Act since you are obtaining this information on behalf of the Minister of National Revenue Furthermore, your officers are regarded as officials or authorized persons thereunder since they are clearly such persons by virtue of the definitions in paragraphs 241(10)(a) and 241(10)(b) respectively. ...