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To the best of your knowledge and that of the taxpayers named above, none of the issues involved in this advance income tax ruling is: in an earlier return of the taxpayers or any related person; being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or any related person;under objection by the taxpayers or any related person; before the courts; or the subject of a ruling previously considered by the Income Tax Rulings Directorate in respect of the taxpayers or any related person. ...

To the best of your knowledge and that of the taxpayers named above, none of the issues involved in this advance income tax ruling is: in an earlier return of the taxpayers or any related person; being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or any related person; under objection by the taxpayers or any related person; before the courts; or the subject of a ruling previously considered by the Income Tax Rulings Directorate in respect of the taxpayers or any related person. ...

To the best of your knowledge and that of the taxpayers named above, none of the issues involved in this advance income tax ruling is: in an earlier return of the taxpayers or any related person; being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or any related person; under objection by the taxpayers or any related person; before the courts; or the subject of a ruling previously considered by the Income Tax Rulings Directorate in respect of the taxpayers or any related person. ...

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 Request are the same as or substantially similar to transactions or issues that are: (a) in a previously filed tax return of the Taxpayers or a related person and; (i) being considered by the CRA in connection with any such tax return; (ii) under objection by the Taxpayers or a related person; (iii) the subject of a current or completed court process involving the Taxpayers or a related person; or (b) the subject of a ruling request previously considered by the Income Tax Ruling Directorate in relation to the Taxpayers or a related person. ...

A similar rationale was expressed in documents 2000-005649 and 2000-0011895 in connection with back to back loans where the Act provides for two income inclusions despite the fact that the inclusions might arguably be traced to the same sum of money. ...

To the best of your knowledge and that of the taxpayers involved, 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 taxpayers or a related person and: A. being considered by the CRA in connection with such return; B. under objection by the taxpayers or a related person; or C. the subject of a current or completed court process involving the taxpayers or a related person; or the subject of a Ruling request previously considered by the Income Tax Rulings Directorate. ...

To the best of your knowledge and that of the taxpayers involved, 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 taxpayers or a related person and: A. being considered by the CRA in connection with such return; B. under objection by the taxpayers or a related person; or C. the subject of a current or completed court process involving the taxpayers or a related person; or ii. the subject of a Ruling request previously considered by the Income Tax Rulings Directorate. ...

Where all of the relevant facts pertaining to a particular situation establish that the feasibility study cannot qualify for treatment as CEE, the costs thereof would be accorded the appropriate treatment described at paragraphs 4 and 5 of Interpretation Bulletin IT-475 and question 28 of the 1986 Revenue Canada Round Table:      Normally, a feasibility study undertaken to determine whether or not a particular course of action is desirable in connection with an existing business is considered to be a current expenditure.  ...

Judicial penalties, which are imposed only in connection with a criminal proceeding, involve either a fine, imprisonment, or both, depending on the criminal offence. 44.      ...

In connection with this method of determining the standby charge, you have referred to paragraph 21 of IT-83R3 which indicates an averaging method (as described therein) is appropriate where an employee and employer agree, and an employee is not assigned an automobile on a long-term basis. ...