Search - connection

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. ...

While the language of this Treaty is not as supportive of the approach (in favour of the taxpayer) adopted by the Courts in connection with the 1942 US Treaty, in Smith the Court held that the old UK Treaty should be interpreted in essentially the same manner as the Courts subsequently held the 1942 US Treaty should be interpreted.  ... Also, on the subsequent period of temporary residence in Canada, the teacher must becoming from Ireland or Denmark and presumably must have some connection to that Country (beyond having simply come from there in transit from somewhere else) in order to have the benefit of the Treaty. (3)     (a)  Paragraph 1(b) of IT-68R2 states that:      "a period not exceeding two years means one period that does not exceed 24 months". 21(1)(b) ...

We also acknowledge your letters of XXXXXXXXXX and our telephone conversations in connection herewith. We understand that, 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 district office or a taxation centre in connection with a tax return already filed, or is under objection or appeal. ...

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. ... XXX 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. ...

Assuming that such a reserve would be established in connection with a self insured benefit plan, the amount of an employer's contribution to a health and welfare trust in respect of such a plan must be based on sound actuarial principles (The establishment of an arbitrary reserve that is contingent is not acceptable.). ... In connection with this comment, we also note that a shareholder or officer would not be considered an employee representative.  ...

JOZWIAK Non-Resident Tax Section Source Deductions Division RE: YOUR REFERENCE: 166-4-4 / 166-1-9-08 / 166-8-13 Disposition by Non-Resident of Income Interest in Trust and XXXX Dear Sirs, Further to our earlier representations in connection with the above matter, our contention remains that the disposition by XXXX of her income interest in the trust involves the realization of a capital asset the proceeds of which are not taxable in Canada pursuant to Article 12(3) of the Canada-United Kingdom Tax Agreement. ... Accordingly, taking into account the very special circumstances of that particular case and the Court's obvious reluctance to disallow the deduction claimed by the appellant, it is our opinion that the comments of Justice Cartwright should not be considered as being binding in connection with the characterization of an income interest in a trust. ...

While the language of this Treaty is not as supportive of the approach (in favour of the taxpayer) adopted by the Courts in connection with the 1942 US Treaty, in Smith the Court held that the old UK Treaty should be interpreted in essentially the same manner as the Courts subsequently held the 1942 US Treaty should be interpreted. ... Also, on the subsequent period of temporary residence in Canada, the teacher must becoming from Ireland or Denmark and presumably must have some connection to that Country (beyond having simply come from there in transit from somewhere else) in order to have the benefit of the Treaty. (3) (a) Paragraph 1(b) of IT-68R2 states that: "a period not exceeding two years means one period that does not exceed 24 months". 21(1)(b) ...

To the best of your knowledge and that of the Taxpayer, none of the proposed transactions or issues involved in this Ruling request are the same as or substantially similar to transactions or issues that are: i. in a previously filed tax return of the Taxpayer or a related person and: A. being considered by the CRA in connection with such return; B. under objection by the Taxpayer or a related person; or C. the subject of a current or completed court process involving the Taxpayer or a related person; or ii. the subject of a Ruling request previously considered by this Directorate. ... No other arrangements will be entered into in connection with the investment or acquisition of property using the Borrowed Funds other than those reasonably required to conclude or complete said investment or acquisition of property. ...

29 September 2022 External T.I. 2022-0949081E5- CMETC-Qualified Engineer or Geoscientist Unedited CRA Tags Subsection 127(9) Principal Issues: (1) What is the status of the "prescribed manner and form" for the certification to be provided by a qualified engineer or geoscientist in connection with the critical minerals exploration tax credit? ... It is anticipated that it will be required to be attached to one of the existing forms that are already required to be completed in connection with a flow-through share offering, such as the T100A. ...

Based on the information you provided, the Artist lives on a reserve and has a strong personal connection to the reserve, which are factors that could be accorded weight in situating the business income to a reserve. ... For example, if the management and business decisions for the Artist such as the negotiation of the contracts for the concerts, are made on the reserve or if the music recordings are produced on the reserve, these factors may indicate a strong connection to the reserve and could situate the Artist’s income on the reserve. ...