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Results 4851 - 4860 of 15551 for connection
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. ...
Miscellaneous severed letter
18 December 1980 Income Tax Severed Letter
By way of exception, the same paragraph provides that wherever the payer may be resident, if he has a permanent establishment in one of the states in connection with which the indebtedness on which the interest is paid was incurred, and that interest is borne by that establishment, then the interest is deemed to arise in the state in which the permanent establishment is situated. ...
Miscellaneous severed letter
15 December 1988 Income Tax Severed Letter 5-7013 - [Interest Deductibility]
We understand that to the best of your knowledge and that of XXXX officials, none of the issues involved in this opinion request is being considered by a District Office or a Taxation Centre in connection with a tax return already filed, and none of the issues is under appeal or objection. ...
Miscellaneous severed letter
10 January 1989 Income Tax Severed Letter
We have been informed that the payments by Hydro in connection with this program involved many customers and totalled over $300 million. ...
Miscellaneous severed letter
27 February 1985 Income Tax Severed Letter
In connection with the IRA, we have said that, by virtue of subsection 75(2), the income of the trust would be taxable in the hands of the beneficiary. ...