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Specifically, you requested the Department's views as to whether the field of architecture is qualified activity and whether an employer would be considered to be carrying on a business in a foreign country to which an employee was sent to perform duties in connection with a contract under which the employer provided architectural services to a construction company resident in that country. ...

Article XI(3)(d) of the Convention is as follows: The interest is beneficially owned by a seller who is a resident of the other Contracting State and is paid by a purchaser in connection with the sale on credit of any equipment, merchandise or services, except where the sale is made between persons dealing with each other not at arm's length. ...

The types of deductions an employee is entitled to claim against employment income is limited to those provided under section 8 of the Act and does not include expenses incurred in connection with a research project carried on by the faculty member. ...

Such a computation is not made where, as here, the land in question was not used or held in connection with the generation of income, whether from business or from the property itself. ...

It states that "passenger vehicle" means an automobile, a station wagon, a passenger van or a similar motor vehicle designed to carry not more than nine persons but does not include an ambulance, a vehicle acquired primarily for use as a taxi or in connection with funerals, a vehicle acquired for hire in the course of a car rental or leasing business or a specially equipped van or pickup truck acquired primarily for the transportation of goods and equipment. ...

Donnelly 613-957-3500 19(1) June 30, 1989 Dear Sirs: Re: Advance Income Tax Ruling Request 24(1) Proposed Note Issue We are writing in connection with your letters of April 25, 1898 and June 9, 1989 and your telephone discussions with Kevin Donnelly on May 11, 1989 and June 19, 1989. ...

Thus, where a yacht is used by a Canadian-controlled private corporation in the Caribbean in connection with an active business carried on primarily in Canada, it may be considered one of those assets all of or substantially all of which were used by the particular corporation in an active business carried on primarily in Canada in meeting the definition of a small business corporation. ...

We note for your information that this position differs from that with respect to amounts received by a tobacco grower in connection with the disposition of a tobacco quota or licence either on the open market or to a government body. ...

Murphy (613)957-2747 June 13, 1988 Dear XXXX Re: XXXX Income Tax Opinion This is in reply to your letter of April 11, 1988 in which you requested pn behalf of XXXX our opinion with respect to the deductibility of interest payments in connection with the proposed transactions described herein. ...

In connection with item 1. above, we noted that there is no line on the form to calculate an amount under paragraph 120.1(3)(b). 3. ...