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XXXXXXXXXX provides investment, asset management, trust and securities custody services, including trustee services in connection with group registered retirement savings plans ("RRSP"). ... To the best of your knowledge and the knowledge of XXXXXXXXXX, none of the issues involved in this ruling request is being considered by a tax services office or taxation centre in connection with an income tax return already filed, and none of the issues is under objection or appeal. ...

In general, for an article to be considered a fixture, some substantial connection with the land or a building on it must be shown. ... In order for an object to be considered a fixture, and thus "real property", some substantial connection with the land or a building on it must be shown. ...

XXXXXXXXXX 970445 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 1997 Dear Sirs: Re: XXXXXXXXXX Advance Income Tax Rulings This is in reply to your letter of XXXXXXXXXX requesting an advance income tax ruling on behalf of the above-referenced taxpayers in connection with the proposed transactions described below and is further to your letters dated XXXXXXXXXX and our telephone conversations on this matter. ... Other Information To the best of your knowledge and that of the taxpayers involved, none of the issues involved in this request are being considered by a Tax Services Office or a Taxation Centre in connection with a tax return already filed, and none of the issues are under appeal or objection. ...

Please note that Guideline 4 requires a) that the employer is resident on a reserve; b) that the employer is an Indian band which has a reserve, or a tribal council representing one or more Indian bands which have reserves, or an Indian organization controlled by one or more such bands or tribal councils, if the organization is dedicated exclusively to the social, cultural, educational, or economic development of Indians who for the most part live on reserves; and c) that the duties of the employment are in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserves. ... Your employment duties would also have to be considered to determine, in accordance with the third requirement of Guideline 4, whether they were in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserves. ...

This latter amount is the total of all amounts that may reasonably be considered to have been claimed as a section 110.6 capital gains deduction by the transferor or any other person with whom the transferee was not dealing at arm's length in connection with the transferor's disposition of the property to the transferee or in connection with any previous disposition of the same property. ...

Thus, (i) Travel expenses incurred in connection with travel from home to a job site and back home from a job site at the end of the day would not qualify for the deduction under paragraph 8(1)(h.1). (ii) Travel expenses incurred in connection with travel between job sites during the course of the work day would qualify for the deduction under paragraph 8(1)(h.1). ...

They import such meanings as "in relation to", "with reference to" or "in connection with". The phrase "in respect of" is probably the widest of any expression intended to convey some connection between two related subject matters.» ...

In order for an employee of an organization which is controlled by a band or tribal council to be exempt under Guideline 4, the organization must be resident on a reserve and must be dedicated exclusively to the social, cultural, educational, or economic development of Indians who for the most part live on reserves; and the duties of the employment must be in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserves. ... In order to fit within Guideline 4, inter alia, the duties of the employment must be in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserves. ...

Whether Form T2200 should be certified with respect to work space in the home on the basis that the employer provides a business telephone and a fax machine in connection with employment duties. 3. ... In the case of your second concern, there are a number of requirements that must be satisfied before an employee is entitled to deduct certain expenses in connection with work space in the home. ...

Please note that Guideline 4 requires a) that the employer is resident on a reserve; b) that the employer is an Indian band which has a reserve, or a tribal council representing one or more Indian bands which have reserves, or an Indian organization controlled by one or more such bands or tribal councils, if the organization is dedicated exclusively to the social, cultural, educational, or economic development of Indians who for the most part live on reserves; and c) that the duties of the employment are in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserves. ... Your employment duties would also have to be considered to determine if, as required under Guideline 4, they were in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserves. ...