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The average amount of actual travel required of each employee varies depending on the job classification. 2) 3) 4) The Department's Position Generally, an automobile allowance paid to an employee will be excluded from income if: (i) the allowance is not in excess of a reasonable amount (subparagraph 6(1)(b)(vii.1) of the Act) or in the case of an employee employed in connection with selling property or negotiating contracts for his employer, is a reasonable amount (subparagraph 6(1)(b)(v) of the Act); (ii) the allowance is based solely on the number of kilometres the vehicle is used to earn employment income (subparagraph 6(1)(b)(x) of the Act) and (iii) the employee is not reimbursed for any expense for the same "use' (kilometres) for which the employee is paid a travel allowance (subparagraph 6(1)(b)(xi) of the Act). the allowances described in your submission for XXXXX are not based on the number of kilometres for which the motor vehicle is used in the course of employment, the allowances are required to be included in income. ...

(b) Whether the guarantee fees arising from or in connection with the loan obligation acquire the same characteristics as interest payments on the loan obligation. ...

You describe a circumstance where the trust governed by a registered retirement savings plan (RRSP) undertakes power of sale proceedings in connection with a mortgage it owns where the mortgagor is unable to remedy his default under it. ...

In this connection, we enclose a copy of Interpretation Bulletin IT-288, which discusses the income tax consequences of gifts of capital property to charities and other institutions. ...

Your concern regarding the plan's status as a Retirement Compensation Arrangement ("RCA") under subsection 248(1) of the Act is that contributions are made to another person, i.e. the trustee of the plan, by employers in connection with benefits that are to be received or enjoyed by the employees on a substantial change in the services rendered by the employees (i.e. the employees would no longer be providing services on becoming disabled). ...

A ruling request must also contain a statement as to whether any of the issues involved are to the best of the taxpayer's knowledge being considered by a District Office and/or Taxation Centre in connection with a tax return already filed, or if any of tee issues are under objection. ...

The loan is incurred in connection with the operation of the Canadian company's permanent establishment in the netherlands and the interest is borne by the permanent establishment. ...

O'Neil Audit Review Division RE Transfer of "Nets and Traps" under subsection 85(1) I.T.A. (7-2240)----------------------------------- This is in reply to your memorandum of November 16, 1982 in connection with the transfer by a fisherman of his "Nets and Traps" to a corporation using the provisions of subsection 85(1) of the Income Tax Act ("Act"). ...

(ii) The contract in connection with which an employee performs duties in a foreign country must be one under which the specified employer CARRIED ON BUSINESS in the foreign country. ...

In this connection, we refer you to paragraph 22 of Interpretation Bulletin IT-428, a copy of which is enclosed for your information. ...