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To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayers 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 taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ...

To the best of your knowledge, and that of the taxpayers involved, other than specifically disclosed in your letter of XXXXXXXXXX, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayers 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 taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...

" As stated in this excerpt, the profit and loss experience is a factor in assessing whether a reasonable expectation of profit is present. ...

The term "Indian", as used in the Guidelines, is defined on page 10 of the Guidelines to mean "an Indian as defined for purposes of the Indian Act ". ...

The terms and conditions of the BCO Loan are as follows: a) The BCO Loan will be repayable in cash or in kind upon demand. b) Interest, at the Applicable Rate, will accrue daily on the outstanding principal amount and be payable periodically on each Payment Date. c) "Payment Date" is defined as XXXXXXXXXX. d) "Quarter " is defined as any 3 consecutive months ending on a Payment Date. e) The "Applicable Rate" of interest for any Quarter is equal to the Applicable Rate of Interest on the Loan plus 10 basis points. f) The first payment date will be XXXXXXXXXX. 8. ...

Brian Arnold's article "Canada Amends Income Tax Convention Interpretation Act " published in Tax Notes International, vol. 18, Number 6, February 8, 1999. ...

" The Supreme Court of Canada found in Savage, 83 DTC 5409 and Nowegijick, 83 DTC 5041 that the words "in respect of" are "... of the widest possible scope. ...

A "qualifying amount" received by an individual in a taxation year means, inter alia, "...an amount (other than the portion of the amount that can reasonably be considered to be received as, on account of, in lieu of payment of or in satisfaction of, interest) that is included in computing the individual's income for the year and is (a) an amount (i) that is received pursuant to an order or judgment of a competent tribunal, an arbitration award or a contract by which the payor and the individual terminate a legal proceeding, and (ii) that is (A) included in computing the individual's income from an office or employment, or (B) received as, on account of, in lieu of payment of or in satisfaction of, damages in respect of the individual's loss of an office or employment, [...]." ...

The Corporation will establish the "XXXXXXXXXX " (the "Plan") for the benefit of its resident and non-resident directors. ...

Cette allocation est payée sous forme d'avance mensuelle représentant un montant de XXXXXXXXXX francs belges, soit environ XXXXXXXXXX $ canadiens. 4. ...