Search - connection

To the best of your knowledge, and that of the taxpayer involved, none of the issues contained herein is, in an earlier tax return of the taxpayer or a related person, being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or a related person or is under objection by the taxpayer or a related person or is the subject of a ruling previously issued and is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ... The Claimant was initially employed by XXXXXXXXXX and in that connection was covered under long term disability insurance policy number XXXXXXXXXX (the "Policy") from XXXXXXXXXX the "Insurer". 2. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues involved in the requested rulings is being considered by a Tax Services Office or a Tax Centre in connection with an income tax return already filed and none of the issues is under objection or appeal. ... Canco XXXXXXXXXX will offer to make loans to employees in connection with their investment XXXXXXXXXX. ...

XXXXXXXXXX You have asked for our interpretation to determine whether there is sufficient connection to a reserve such that the employees’ income is tax-exempt. ... It also requires 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 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. ...

In connection with your request, you have provided us with a copy of the decision (the “Decision”) rendered by the Supreme Court of Newfoundland (the “Court”). ... In connection with the award of $XXXXXXXXXX, you have advised that XXXXXXXXXX paid the amount to Individual B and issued a T4A slip on the basis that the amount represented self-employment income to Individual B. ...

The relevant terms of the Trust are as follows: (a) The Trust will be established to provide benefits to the Taxpayer in connection with the taxpayer's retirement from his employment with the Employer. ... To the best of your knowledge and the knowledge of the Taxpayer, none of the issues involved in this request for an advance income tax ruling: (a) is in an earlier return of the Taxpayer or of a person related to the Taxpayer; (b) is being considered by a tax services office or taxation centre in connection with a previously filed return of the Taxpayer or of a person related to the Taxpayer; (c) is under objection by the Taxpayer or by a person related to the Taxpayer; (d) is before the courts; or (e) is the subject of a ruling previously issued by the Income Tax Rulings and Interpretations Directorate. ...

Subsection 80.4(1) of the Act deems an interest benefit to arise where a taxpayer has received a low interest or interest-free loan in connection with a previous, current or intended office or employment. ... Moreover, the interest-free loans, under the proposed program, are not in connection with a previous, current or intended office or employment. ...

We also acknowledge the information provided in subsequent correspondence and during our various telephone conversations in connection with your request. We understand that, to the best of your knowledge and that of the taxpayer, none of the issues involved in the ruling request is: (i) in an earlier return of the taxpayer 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 taxpayer or a related person; (iii) under objection by the taxpayer or a related person; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (v) the subject of a Ruling previously issued by this Directorate. ...

We also acknowledge the information provided in subsequent correspondence and during our various telephone conversations in connection with your request. We understand that, to the best of your knowledge and that of the taxpayer involved, none of the issues involved in this ruling request: (i) is in a previously filed tax return of the taxpayer or a related person; (ii) is being considered by a Tax Services Office or Taxation Centre in connection with a previously filed tax return of the taxpayer or a related person; (iii) is under objection by the taxpayer or a related person; (iv) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (v) is the subject of a ruling previously issued by this Directorate. ...

What is the current CRA work situation in connection with the conduct of international audits and requests for foreign based information? ...

Stavanger Municipality, concerns a Swedish taxpayer operating a consulting company that was hired in connection with the hook-up of a drilling platform on the Norwegian continental shelf.  ... A legal opinion dated December 3, 1990 written by Francois Vincent of the Department of Justice deals with a similar situation involving 24(1) That opinion, a copy of which was sent to your Division, supports the views we expressed above. 24(1) In connection with this point, we note that Article VII of the 1980 Convention attributes business profits earned in Canada by a U.S. resident to a P.E. in Canada but, as stated in paragraph 7 thereof, only to the extent they are derived from the assets or activities of that P.E. ...