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Results 5401 - 5410 of 5529 for connection
Ruling

2008 Ruling 2007-0241221R3 - 55(3)(b) butterfly reorganization

No section 85 election will be filed in connection with such exchanges, the parties relying instead on section 51. 17. ... No section 85 election will be filed in connection with such exchanges, the parties relying instead on section 51. ... The amount shall be designated pursuant to the resolution of the directors of Subco A and Transferee Z, as the case may be, made in connection with the issuance of such share. ...
Ruling

2006 Ruling 2006-0181061R3 - Butterfly Distribution - XXXXXXXXXX

You have advised us that to the best of your knowledge and that of the taxpayer involved none of the issues involved in this ruling request: (i) in an earlier return of the taxpayer 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 taxpayer 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. ...
Ruling

2005 Ruling 2004-0106481R3 - Employee benefit plan-Shares

To the best of your knowledge, none of the issues involved in this Ruling are: (i) in an earlier tax return of the Corporation, a Participant or any person related to the Corporation or a Participant; (ii) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Corporation, a Participant or any person related to the Corporation or a Participant; (iii) under objection by the Corporation, a Participant or any person related to the Corporation or a Participant; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; nor (v) the subject of a ruling previously issued by the Directorate to the Corporation, a Participant or any person related to the Corporation or a Participant. ...
Ruling

2013 Ruling 2012-0449611R3 - single-wing butterfly reorganization

To the best of your knowledge, and that of the above-referenced taxpayer involved, none of the issues involved in this ruling request 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, 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

2013 Ruling 2012-0435221R3 - CCPC SAR Plan

We understand that, to the best of your knowledge and that of the above-referenced Company, none of the issues involved in the ruling request is: (i) in an earlier return of the Company or a related person; (ii) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Company or a related person; (iii) under objection by the Company or a related person; (iv) before the courts; nor, (v) the subject of a ruling previously issued by the Directorate, except with respect to Ruling 2006-0201541R3 on the Current Plan. ...
Ruling

2014 Ruling 2013-0505431R3 - XXXXXXXXXX

To the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling request is: (a) in an earlier income tax return of the taxpayer or a related person; (b) being considered by a Tax Services Office or Taxation Centre in connection with a previously filed income tax return of the taxpayer or a related person; (c) under objection by the taxpayer or a related person; (d) before the courts; or (e) the subject of a ruling previously issued by the Income Tax Rulings Directorate involving the taxpayer or a related person. ...
Ruling

2011 Ruling 2010-0367251R3 - Loss Consolidation

To the best of your knowledge and that of the above-referenced taxpayers, none of the issues involved in this ruling is: (i) dealt with in an earlier return of any of the above-referenced 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 any of the above-referenced taxpayers or a related person, (iii) under objection or appeal by any of the above-referenced 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 by the Income Tax Rulings Directorate. ...
Ruling

2010 Ruling 2010-0365371R3 - Cross-Border Restructuring

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

16 August 2011 External T.I. 2009-0342101E5 - Operation of Ships

If, in fact, that cargo handling operation had developed to a stage where it was beyond any reasonable requirements of the company's own ships, it would seem appropriate to treat it as a separate business and, in the context of the question at hand, to exclude those revenues arising in connection with cargo services provided to the other ship owners. ...
Ruling

2009 Ruling 2008-0284591R3 - Split-up Butterfly

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 persons related to the taxpayers; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or persons related to the taxpayers; (iii) under objection by the taxpayers or persons related to 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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