Search - connection

Results 5021 - 5030 of 5530 for connection
Ruling

2005 Ruling 2005-0113461R3 - Application of 111(5)(e) - acquisition of control

You have advised us that to the best of your knowledge and that of the taxpayers involved none of the issues involved in this ruling request are: (i) in an earlier return of the taxpayers or related persons; (ii) being considered by a tax services office ("TSO") or taxation centre ("TC") in connection with a previously filed tax return of the taxpayers or related persons; (iii) under objection by the taxpayers or related persons; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...
Ruling

2006 Ruling 2005-0126261R3 - Taxation of Indian Trust

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 (v) the subject of a ruling previously issued by the Directorate to the taxpayer or a related person. ...
Ruling

2006 Ruling 2006-0171011R3 - Withholding - on Loan to a partnership

To the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling request are: (i) dealt with in an earlier return of the taxpayers or related persons; (ii) being considered by a tax services office or a taxation centre in connection with a previously filed tax return of the taxpayers or related persons; (iii) under objection by the taxpayers or related persons; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; or (v) subject to a ruling previously issued by the Income Tax Rulings Directorate to the taxpayers or related persons. ...
Ruling

2006 Ruling 2006-0172311R3 - Appl. of s.111(5)(a)(ii) - acquisition of cont.

You have advised us that to the best of your knowledge and that of the taxpayers involved, none of the issues involved in this ruling request are: (i) in an earlier return of the taxpayers or related persons; (ii) being considered by a tax services office ("TSO") or taxation centre ("TC") in connection with a previously filed tax return of the taxpayers or related persons; (iii) under objection by the taxpayers or related persons; (iv) before the Courts; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...
Ruling

2006 Ruling 2005-0147681R3 - Transfer of CRP

We understand that to the best of your knowledge and that of the taxpayers involved, none of the issues contained herein: (i) is included in an earlier return of any of the taxpayers 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 taxpayers or a related person; (iii) is under objection by the taxpayers or a related person; (iv) is before the courts; and (v) is the subject of a previous ruling issued by the Income Tax Rulings Directorate. ...
Ruling

2006 Ruling 2004-0105021R3 - bituminous sands in-situ - 1 project

We understand that to the best of your knowledge and that of the taxpayers involved, none of the issues contained herein: (i) is included in an earlier return of the taxpayers 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 taxpayers or a related person; (iii) is under objection by the taxpayers or a related person; (iv) is before the courts; and (v) is the subject of a previous ruling issued by the Income Tax Rulings Directorate. ...
Ruling

2006 Ruling 2006-0171291R3 - Loss Utilization

We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling request herein is: (i) dealt with in an earlier return of Amalco, Opco, Lossco, Newco or a related person; (ii) being considered by a tax services office or a taxation centre in connection with a tax return already filed by Amalco, Opco, Lossco, Newco or a related person; (iii) under objection by Amalco, Opco, Lossco, Newco 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 expired, or (v) the subject of a previous ruling issued by the Income Tax Rulings Directorate to the taxpayers or a related person. ...
Ruling

2006 Ruling 2005-0158461R3 - Single-wing butterfly - XXXXXXXXXX

You have advised us that to the best of your knowledge and that of the taxpayer involved none of the issues involved in this ruling request are: (i) in an earlier return of the taxpayer or any related person; (ii) being considered by a tax services office ("TSO") or taxation centre ("TC") in connection with a previously filed tax return by the taxpayer or any related person; (iii) under objection by the taxpayers or any related person; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...
Ruling

2006 Ruling 2006-0177231R3 - convert from a closed-end to open-end unit trust

To the best of your knowledge and that of your client, none of the issues involved in the ruling request is: in an earlier return of your client or a related person, being considered by a tax services office or taxation center in connection with a previously filed tax return of your client or a related person, under objection by your client or a related person, before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired, or the subject of a ruling previously considered by the Directorate in respect of your client or a related person. ...
Ruling

2006 Ruling 2005-0143361R3 - split assets of 3 trusts into 5 separate trusts

To the best of your knowledge and that of your client, none of the issues involved in the ruling request is: in an earlier return of your client or a related person, being considered by a tax services office or taxation center in connection with a previously filed tax return of your client or a related person, under objection by your client or a related person, before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired, or the subject of a ruling previously considered by the Directorate in respect of your client or a related person. ...

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