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Miscellaneous severed letter

24 February 1992 Income Tax Severed Letter 9206085 - 1992 Manitoba Canadian Bar Association/CICA Roundtable

Manitoba Property Tax Credits Question 9 In connection with Manitoba property tax credits, there have been instances where clients have paid property taxes but have not received the homeowners assistance. ...
Ruling

2021 Ruling 2021-0879141R3 - Advance Income Tax Ruling - XXXXXXXXXX Butterfly

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. ...
Ruling

2021 Ruling 2020-0870761R3 - Standard Loss Consolidation Ruling

We understand that, 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 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; 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. ...
Miscellaneous severed letter

7 July 1996 Income Tax Severed Letter 9617323 - Single-wing butterfly — assumption of liabilities

To the best of your knowledge, none of the issues involved in this advance ruling request is being considered by a Tax Services Office or a Taxation Centre in connection with a tax return already filed and none of the issues is under objection. ...
Conference

24 February 1992 Roundtable, 9206080 F - 92 Manitoba CBA/CICA Roundtable

Manitoba Property Tax Credits Question 9 In connection with Manitoba property tax credits, there have been instances where clients have paid property taxes but have not received the homeowners assistance.  ...
Ruling

2021 Ruling 2021-0906111R3 - XXXXXXXXXX Post-mortem Pipeline

The tax account numbers, Tax Services Offices, and Tax Centres of the taxpayers involved are as follows: XXXXXXXXXX (collectively, the “Taxpayers”) We understand that to the best of your knowledge and that of the Taxpayers, none of the Proposed Transactions or issues involved in this Ruling 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 such return; ii. under objection by the Taxpayers or a related person; or 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 Rulings Directorate. ...
Technical Interpretation - Internal

21 September 2021 Internal T.I. 2019-0807491I7 - Subsections 93.1(5) and (6)

Any references or discussion in this document pertaining to the characterization of LLC2’s interest as FAPI or as ABI is in connection with the characterization of the income in respect of USP only. ...
Ruling

2022 Ruling 2021-0910431R3 - Loss consolidation arrangement

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. ...
Ruling

2023 Ruling 2023-0961681R3 - CEE Incurred by a Non-resident

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 Canada Revenue Agency 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. ...
Ruling

2024 Ruling 2022-0948081R3 - Loss Consolidation Arrangement

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. ...

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