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(iii) the total of all amounts including amounts in respect of utilities, included in computing the taxpayer's income for the year under section 6 in respect of the residence or other living accommodation occupied by the taxpayer in the course of, or because of, the taxpayer's office or employment as such a member or minister so in charge of or ministering to a diocese, parish or congregation, or so engaged in such administrative service, or (iv) rent and utilities paid by the taxpayer for the taxpayer's principal place of residence (or other principal living accommodation), ordinarily occupied during the year by the taxpayer, or the fair rental value of such a residence (or other living accommodation), including utilities, owned by the taxpayer or the taxpayer's spouse or common-law partner, not exceeding the lesser of (A) the greater of (I) $1,000 multiplied by the number of months (to a maximum of ten) in the year, during which the taxpayer is a person described in subparagraphs (i) and (ii), and (II) one-third of the taxpayer's remuneration for the year from the office or employment, and (B) the amount, if any, by which (I) the rent paid or the fair rental value of the residence or living accommodation, including utilities exceeds (II) the total of all amounts each of which is an amount deducted, in connection with the same accommodation or residence, in computing an individual's income for the year from an office or employment or from a business (other than an amount deducted under this paragraph by the taxpayer), to the extent that the amount can reasonably be considered to relate to the period, or a portion of the period, in respect of which an amount is claimed by the taxpayer under this paragraph." Basically, in a situation where spouses who are clergy members, rent or own their home, the provision limits the amount of deduction, for each particular spouse, to the least of the following three amounts: 1. the particular spouse's remuneration for the year from the office or employment [paragraph 8(1)(c) mid-amble], 2. the greater of $1,000 per month (to a maximum of ten months) in the year during which the particular spouse meets the conditions set out in subparagraphs 8(1)(c)(i) and (ii), [subclause 8(1)(c)(iv)(A)(I))], and 1/3 of the particular spouse's total remuneration from the employment for the year [subclause 8(1)(c)(iv)(A)(II)], and 3. the rent paid or the fair rental value of the residence including utilities (this amount must be reduced by the total of all other amounts deducted in computing either spouse's income from a business or from an office or employment in connection with the residence other than the particular spouse's clergy residence deduction). ...

Thus, the connection between the employment and the land upon which the employer is located is not as strong in the present situation as it was in Amos or Boubard. ... In our view, the fact that the land XXXXXXXXXX should not be given significant weight, as there appears to be no connection between XXXXXXXXXX and the present employment opportunities at XXXXXXXXXX. ...

If the investment product constitutes a life insurance policy, the proposed FIE rules contain specific provisions governing the tax treatment of an interest in the life insurance policy with respect to the taxation in Canada of income earned in connection with a life insurance policy. As noted above, where proposed subsection 94.2(11) in former Bill C-10 applies to deem the interest in the life insurance policy to be a participating interest in a non-resident entity, the taxation of income earned in connection with the life insurance policy would be determined with reference to the FIE rules. ...

Under certain circumstances, paragraph 8(1)(f) of the Act allows for deductions pertaining to sales expenses where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for the taxpayer's employer. ... For example, a real estate agent may deduct legal fees in a defence against charges of misrepresentation in connection with an aborted sale of property. ...

We understand that to the best of your knowledge, and that of the taxpayers involved, none of the matters considered in this ruling request are: a) dealt with in an earlier return of the taxpayers or a related person; b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the taxpayers or a related person; c) under objection by one or any of the taxpayers or a related person; d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; and e) the subject of a ruling previously issued by this Directorate. ... Opco1 will receive reimbursement of all expenses incurred in connection with the recruiting and administrative effort plus a XXXXXXXXXX% mark-up. 14. ...

Since the elder child is attending school in the United States, the family has decided to move south, closer to old family connections. ...

We understand that, to the best of your knowledge and that of the above-referenced taxpayer, none of the issues involved in the supplemental ruling request is: (i) in an earlier return of the Corporation or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the Corporation or a related person; (iii) under objection by the Corporation or a related person; (iv) before the courts or under appeal; nor, (v) the subject of a ruling previously issued by the Directorate, other than in the Ruling or in the Supplemental Ruling. ... The Corporation will pay all brokerage fees arising in connection with the acquisition of Common Shares by the Broker on the open market and may make a special cash payment to the Participant in an amount sufficient to cover any income tax liability of the Participant as a consequence of both the special cash payment for fractional Share Units and the payment of such brokerage fees by the Corporation. ...

Paragraph 25 of IT-268R4, to which you made reference, deals with a leasing arrangement in connection with a transfer under subsection 73(3). ... An analogous comment would apply with respect to paragraph 14 of IT-349R3, which deals with a leasing arrangement in connection with a transfer under subsection 70(9). ...

You have requested our views as to whether certain expenses incurred in connection with this project will qualify as CRCE. ... Examples of the types of expenses that are eligible for CRCE are described in subsection 1219(1) of the Regulations and include: (a) expenses incurred for the purposes of making a service connection to the project for the transmission of electricity to a purchaser of the electricity, to the extent the expense was not incurred to acquire property; (b) expenses incurred for the construction of a temporary access road to the project site; (c) expenses incurred for a right of access to the project site before the earliest time at which a property described in Class 43.1 or 43.2 is used in the project for the purpose of earning income; (d) expenses incurred for clearing land to the extent necessary to complete the project; and (e) expenses incurred for process engineering for the project, including (i) collection and analysis of site data, (ii) calculation of energy, mass, water or air balances, (iii) simulation and analysis of performance and cost of process design options, and (iv) selection of the optimum process design. ...

One of the conditions is that all or substantially all of the individual's employment duties must be performed outside Canada in connection with a contract under which the employer carried on business outside Canada with respect to a qualifying activity or for the purpose of obtaining a contract for the specified employer to undertake a qualifying activity. ... If the construction, installation or engineering activities are not the primary and most important activities of the Canadian corporation in connection with the particular contract, the employees performing the duties outside Canada cannot claim the OETC provided for in section 122.3 of the Act as at least one of the requirements of section 122.3 of the Act is not met. ...