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Ruling

2008 Ruling 2008-0273471R3 - XXXXXXXXXX Ruling Request

We understand that, to the best of your knowledge and that of the Taxpayers, none of the issues involved in the ruling request is: (i) 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, or (iv) before the courts. ...
Ruling

2009 Ruling 2007-0251621R3 - Split-Up Butterfly

You have advised that to the best of your knowledge, and that of the responsible officers of each of the taxpayers, none of the issues involved in this Ruling is (a) in an earlier tax return of one of the taxpayers or any related person; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of one of the taxpayers or a related person; (c) under objection by one of the taxpayers or a related person; (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (e) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...
Ruling

2009 Ruling 2007-0261171R3 - Post butterfly transaction

To the best of your knowledge and that of each of the taxpayers, none of the issues involved in this ruling request is: in an earlier return of any of the taxpayers or a related person; 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; under objection by any of the taxpayers or a related person; before the courts; or the subject of a ruling previously issued by the Income Tax Rulings Directorate other than the advance income tax ruling issued on XXXXXXXXXX, 2006 (our reference 2006-020398) (the "Original Ruling") and the advance income tax ruling issued on XXXXXXXXXX, 2007 (our reference 2007-0232261R3)(the "Second Ruling"). ...
Ruling

2009 Ruling 2008-0297571R3 - Loss

To the best of your knowledge, and that of the Taxpayers, none of the issues involved in this advance income tax ruling are: (i) in an earlier return of any of the Taxpayers or a related person; (ii) being considered by a Tax Services Office or a Taxation 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) 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 to any of the Taxpayers by the Income Tax Rulings Directorate. ...
Ruling

2009 Ruling 2009-0308611R3 - Alter Ego Trust

We also acknowledge the additional information provided in your subsequent correspondence dated XXXXXXXXXX We understand that, to the best of your knowledge and that of the taxpayers, none of the issues involved in the ruling request is: a) in an earlier tax return of the taxpayers or of any related persons; b) being considered by a tax services office or a tax centre in connection with a tax return already filed by the taxpayers or by any related persons; c) under objection by the taxpayers or any related persons; d) before the courts or, e) the subject of a ruling previously issued by the Directorate to the taxpayers or to any related persons. ...
Ruling

2008 Ruling 2007-0249451R3 - Split-up butterfly

To the best of your knowledge, and that of the taxpayer involved, none of the issues involved in this 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, 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

2008 Ruling 2008-0292121R3 - Alter ego trust for XXXXXXXXXX

We understand that, to the best of your knowledge and that of the Taxpayers, none of the issues involved in the ruling is: (i) 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; or (iv) before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...
Ruling

2007 Ruling 2006-0212481R3 - Reorganization of a mutual fund trust

We understand that to the best of your knowledge, and that of the taxpayers involved, none of the matters considered in this ruling request are: a) dealt with in an earlier return of the taxpayers or a related person; b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the taxpayers or a related person; c) under objection by one or any of the taxpayers or a related person; d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; and e) the subject of a ruling previously issued by this Directorate. ...
Ruling

2007 Ruling 2006-0217481R3 - Corporate Reorganization

In connection with the amalgamation described in paragraph 44 above, in its first taxation year commencing at the time of the amalgamation, Canco #3 will file a designation pursuant to paragraph 88(1)(d) of the Act to increase, within the limits described therein, the ACB of the shares of FA#1 and the shares of Foreignco #6 that Canco #1 owned without interruption at and since the time that Canco #2 last acquired control of Canco #1 and that became property of Canco #3 pursuant to the amalgamation. ...
Ruling

2007 Ruling 2007-0231521R3 - Eligible Dividend Designations

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

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