Search - connection

To the best of your knowledge and that of the above-referenced taxpayer, none of the issues involved in this ruling is: (i) in an earlier return of the above-referenced 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 above-referenced taxpayer or a related person; (iii) under objection by the above-referenced taxpayer or a related person; (iv) before the courts; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

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) in an earlier return of the taxpayers or related persons; b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the taxpayers or related persons; c) under objection by the taxpayers or related persons; d) before the courts; or e) the subject of a ruling previously issued by this Directorate to the taxpayers or related persons. ...

To the best of your knowledge, and that of the taxpayer involved, none of the issues contained herein: (i) is in an earlier return of the taxpayer 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 taxpayer or a related person; (iii) is under objection by the taxpayer or a related person; (iv) is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has expired; or (v) is the subject of a ruling previously issued by this Directorate. ...

CRA Response to Question 14.1 During the 1981 Revenue Canada Round Table of the Canadian Tax Foundation, the CRA indicated that it would not challenge the reasonableness of salaries and bonuses paid to principal shareholders-managers of a corporation when: the general practice of the corporation is to distribute the profits of the corporation in the form of bonuses or additional salaries; the corporation has adopted a policy of declaring bonuses to the shareholders to remunerate them for the profits the corporation has earned that are, in fact, attributable to the special know-how, connections, or entrepreneurial skills of the shareholders. ...

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 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 taxpayers 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. ...

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. ...

To the best of your knowledge and that of the above-mentioned taxpayers, none of the issues involved in the ruling request: (i) is 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, or (iv) is before the courts. ...

To the best of your knowledge, and that of the taxpayer, none of the issues in this ruling request is: (i) involved 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 Income Tax Rulings Directorate. ...

To the best of your knowledge and that of Pubco, none of the issues involved in this ruling request is: 1. in an earlier return of Pubco or a related person; 2. being considered by a tax services office or taxation centre in connection with a previously filed tax return of Pubco or a related person; 3. under objection by Pubco or a related person; 4. before the courts; or 5. the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

To the best of the knowledge of the taxpayers, none of the issues described herein is: (a) in an earlier return; (b) being considered by a tax services office or taxation centre in connection with any tax return previously filed; (c) the subject of any notice of objection or is under appeal; or (d) the subject of a previously issued ruling. ...