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Ruling
2012 Ruling 2011-0427951R3 - Loss Consolidation
“Proposed Transactions” means the transactions described in 22 – 38 below; v. ...
Ruling
2014 Ruling 2014-0518521R3 - Issuance of a new class of units - Hedged Class
XXXXXXXXXX 2014-051852 XXXXXXXXXX, 2014 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX (the "Taxpayer") BN: XXXXXXXXXX This is in response to your letter dated XXXXXXXXXX wherein you requested an advance income tax ruling on behalf of the Taxpayer. ...
Technical Interpretation - Internal
21 October 2015 Internal T.I. 2015-0592781I7 - treatment of bond locks
Frost and as evidenced by Standard & Poor's credit watch discussed above. ...
Ruling
2010 Ruling 2009-0341561R3 - Irish CCF
The Units will not have any voting rights (save the right, on written notice signed by Unitholders holding XXXXXXXXXX % of the Units, to require the Manager to resign). ...
Ruling
2011 Ruling 2010-0363361R3 - Group Contribution Payments
Yours truly, XXXXXXXXXX, Manager For Director International & Trusts Division Income Tax Rulings Directorate ...
Ruling
2015 Ruling 2015-0574901R3 - Qualifying environmental trust
Yours truly, XXXXXXXXXX Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...
Ruling
2008 Ruling 2008-0289491R3 - Ptnshp contracting out pro services to ptnr's corp
The members of the Second Partnership derive XXXXXXXXXX %, of their Professional Services income from the Second Partnership. ...
Ruling
2017 Ruling 2016-0635341R3 - Canadian Exploration Expenses - New Mine
Yours truly, XXXXXXXXXX Acting Manager, Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...
Ruling
2008 Ruling 2007-0245931R3 - Partnership Reorg-Personal Services Business
Collectively they are referred to as the "Partners"; (o) "Partnership" means the partnership, which currently carries on the Practice under the firm name "XXXXXXXXXX ". ...
Ruling
2008 Ruling 2007-0246051R3 - Partnership Reorg- personal services business
For purposes of this paragraph, " family" means individuals connected by blood relationship, marriage, common-law partnership or adoption, as those terms are described in subsection 251(6) of the Act. 15. ...