Search - connection
Results 5511 - 5520 of 5527 for connection
Ruling
2000 Ruling 1999-0010893 - XXXXXXXXXX ruling
You have advised that to the best of your knowledge and that of the taxpayers involved none of the issues involved in this ruling request: (a) is involved in an earlier return of the taxpayers or a related person, (b) is being considered by a tax services office or taxation centre in connection with a tax return already filed by the taxpayers or a related person, (c) is under objection, (d) is before the courts or, if a judgement has been issued, the time limit for appeal has not expired, and (e) is the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...
Ruling
2000 Ruling 1999-0010723 - sequential butterfly reorganizations
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 one 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 one of the taxpayers or a related person; (iii) is under objection by one of the taxpayers or a related person; (iv) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (v) is the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...
Miscellaneous severed letter
7 July 1996 Income Tax Severed Letter 9604323 - Reorganization
We understand that to the best of your knowledge and that of the taxpayers involved none of the issues involved in the requested rulings is being considered by a taxation services office or a taxation centre in connection with a tax return already filed, or is under objection or appeal. ...
Ruling
2020 Ruling 2020-0853221R3 - Split-up butterfly: investment company
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
2013 Ruling 2013-0491651R3 - Cross-Border Butterfly
You have advised that, to the best of your knowledge, and that of the taxpayer, none of the issues involved in this ruling request: 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 judgment has been issued, the time limit for appeal to a higher court has not expired; or v. is the subject of a ruling previously issued by this directorate. ...
Ruling
2016 Ruling 2015-0569561R3 - 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 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, 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. ...
Conference
20 January 1997 CTF Roundtable Q. 1, 9604996 - : Article XXIX B of Canada-U.S. Treaty
The marital credit is allowed only in connection with transfers satisfying each of the following five conditions. ...
Conference
9 October 1998 APFF Roundtable Q. 1, 9M18520 - ROUND TABLE 1998 APFF
The approach adopted by the government will be reflected in the draft legislation which will be made public shortly in connection with the most recent budget proposals. ...
Ruling
2000 Ruling 2000-0048083 - butterfly reorganization
You have been advised by your clients that none of the issues contained herein is: (i) in an earlier return of the taxpayers or related persons; (ii) being considered by a Tax Services Office or Taxation Centre in connection with a previously filed tax return of the taxpayers or related persons; (iii) under objection by the taxpayers or related persons; (iv) before the courts; or (v) the subject of a ruling previously issued by the Directorate. ...
Ruling
2001 Ruling 2001-0084793 - Butterfly
You have been advised by your clients that to the best of their knowledge, none of the issues involved in this ruling, as they apply specifically to such parties:- is in an earlier return;- is being considered by a tax services office or taxation centre in connection with a previously filed tax return;- is under objection;- is before the courts; or- is the subject of a previously issued ruling. ...