Search - connection
Results 5491 - 5500 of 5531 for connection
Ruling
2008 Ruling 2007-0240881R3 - 55(3)(b) Butterfly reorganization
We understand that to the best of your knowledge and that of the taxpayers on whose behalf this ruling is being requested, none of the issues involved in this ruling request (i) is in an earlier return of any of such 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 any such taxpayers or a related person, (iii) is under objection by any of such taxpayers or a related person, (iv) is, in relation to any of such taxpayers or a related person, before the courts or is the subject of a judgment the time limit for appeal from which has not expired, or (v) is the subject of a ruling previously considered by the Directorate in relation to any of such taxpayers or a related person. ...
Ruling
2008 Ruling 2007-0221361R3 - Alter Ego Trust Planning
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. ...
Ruling
2005 Ruling 2005-0126061R3 - Butterfly reorganization
To the best of your knowledge and that of The Group, none of the issues involved in this ruling: (a) relates to an earlier income tax return of The Group or a person related to The Group; (b) is being considered by a tax services office or taxation centre in connection with a previously filed tax return of The Group or a person related to The Group; (c) is under objection by The Group or a person related to The Group; (d) is before the courts; or (e) is the subject of a ruling previously considered by the Directorate. ...
Ruling
2007 Ruling 2006-0218911R3 - 132.2 reorganization with an internal butterfly
To the best of your knowledge and that of the above-referenced taxpayer, none of the issues involved in this ruling is: (a) in an earlier return of the above-referenced taxpayer or a related person; (b) 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; (c) under objection by the above-referenced taxpayer or a related person; (d) before the courts; or (e) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...
Ruling
2005 Ruling 2005-0113301R3 - Butterfly
To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (a) dealt with in an earlier return of the taxpayers or related persons; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or related persons; (c) under objection by one or any of the taxpayers or related persons; (d) the subject of a ruling previously issued by the Income Tax Rulings Directorate; or (e) before the courts. ...
Ruling
2018 Ruling 2017-0683941R3 - Split-up transactions
To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in this ruling request is: (i) in a previously filed tax 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) the subject of a current or completed court process involving the taxpayers or persons related to the taxpayers; or (v) the subject of an advance income ruling previously issued by the Income Tax Rulings Directorate. ...
Ruling
30 November 1996 Ruling 9629733 - BUTTERFLY RULING (XXXXXXXXXX)
To the best of your knowledge and that of the taxpayers involved: (i)none of the issues involved in the requested rulings is being considered by a Tax Services Office or a Taxation Centre in connection with a tax return already filed, and (ii)none of the issues involved in the requested rulings is the subject of any notice of objection or is under appeal. ...
Ruling
30 November 1995 Ruling 9617343 - REORGANIZATION, INTERLOCKING SHAREHOLDINGS
To the best of your knowledge, and that of the parties to this ruling, none of the issues contained in this advance income tax ruling is being considered by a Tax Services Office and/or a Taxation Centre in connection with an income tax return previously filed and none of the issues contained herein is under objection or appeal. ...
Ruling
30 November 1997 Ruling 9800973 - BUTTERFLY RULING (SPIN-OFF)
To the best of your knowledge, and that of the taxpayers 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; or (iv) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...
Ruling
30 November 1997 Ruling 9722003 - REORGANIZATION, ATTRIBUTION
To the best of your knowledge, and that of the parties to this ruling, none of the issues contained in this advance income tax ruling: 1. is in an earlier return of the taxpayer or a related person, 2. is being considered by a tax services office or a taxation centre in connection with a previously filed tax return of the taxpayer or a related person, 3. is under objection by the taxpayer or related person, 4. is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired, or 5. is the subject of a ruling previously issued by the Directorate. ...