Search - connection
Results 5201 - 5210 of 5529 for connection
Ruling
1999 Ruling 9909773 - DISCOUNT ON BONDS
To the best of your knowledge and that of XXXXXXXXXX, none of the issues in respect of which rulings are herein requested is currently under consideration by a tax services office or taxation centre in connection with a tax return or notice of objection already filed. ...
Ruling
1999 Ruling 9911123 - SINGLE WING BUTTERFLY
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 judgment has been issued, the time limit for appeal to a higher court has not expired. ...
Ruling
1999 Ruling 9902613 - STAPLED SHARES - CROSS-BORDER REORGANIZATION
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. ...
Ruling
1998 Ruling 973303 - XXXXXXXXXX
To the best of the knowledge of you and the responsible officers of the Applicants, none of the issues involved in the requested rulings is:- in an earlier return of the Applicants or related persons;- being considered by a tax services office or tax centre in connection with a tax return of the Applicants or related persons;- under objection by the Applicants or related persons;- before the courts; or- the subject of a ruling previously issued by this Directorate to the Applicants or related persons. ...
Ruling
1998 Ruling 9825863 - 107(2),107(4.1) AND 55(2)
To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein: (i) is 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 any of the taxpayers or a related person; (iii)is under objection by the any of the taxpayers or a related person; or (iv)is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...
Ruling
1998 Ruling 9826013 - MUTUAL FUND TRUST
We understand that to the best of your knowledge and that of the taxpayers, none of the issues involved in this ruling request: (a) are in an earlier return of the taxpayers or a related person; (b) are 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; (c) are under objection by the taxpayers or a related person; (d) are before the courts; or (e) are the subject of a ruling previously issued by this Directorate to the taxpayers or a related person. ...
Ruling
2016 Ruling 2016-0630761R3 - Transfer of Shares
We understand that, to the best of your knowledge and that of the above-named taxpayers, none of the issues involved in the ruling request is: (i) in an earlier tax return of the above-named taxpayers or a related person; (ii) being considered by a tax services office or a tax centre in connection with a tax return already filed by the above-named taxpayers or a related person; (iii) under objection by the above-named taxpayers 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 the Directorate to the above-named taxpayers or a related person. ...
Ruling
2017 Ruling 2017-0693751R3 - Transfer of Shares of a Foreign Affiliate
You have represented to us that, to the best of your knowledge and that of the above-named taxpayers, none of the issues involved in the ruling request is: (i) in a previously filed tax return of the above-named taxpayers or a related person; (ii) being considered by a tax services office or a tax centre in connection with a tax return previously filed by the above-named taxpayers or a related person; (iii) under objection by the above-named taxpayers or a related person; (iv) the subject of a current or completed court process involving the above-named taxpayers or a related person; or (v) except as noted below, the subject of a Ruling request previously considered by this Directorate. ...
Ruling
2018 Ruling 2018-0742641R3 - Loss consolidation arrangement
To the best of your knowledge and that of the Taxpayers, none of the issues involved in the ruling request is: i. in a previously filed tax return of any of the Taxpayers or a related person; ii. being considered by a tax services office or a tax centre in connection with a previously filed tax return of any of the Taxpayers or a related person; iii. under objection by any of the Taxpayers or a related person; iv. the subject of a current or completed court process involving the Taxpayers or a related person; or v. the subject of a ruling request previously considered by the Directorate. ...
Ruling
2018 Ruling 2018-0767431R3 - Post-mortem pipeline
We understand that to the best of your knowledge and that of the Taxpayers, none of the proposed transactions and/or issues involved in this Ruling are the same as or substantially similar to transactions and/or issues that are: (a) in a previously filed return of the Taxpayers or a related person; (b) 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; (c) under objection by the Taxpayers or a related person; (d) the subject of a current or completed court process involving the Taxpayers or a related person; or (e) the subject of a ruling previously considered by the Income Tax Rulings Directorate in relation to the Taxpayers or a related person. ...