Search - connection

Results 5521 - 5530 of 5530 for connection
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. ...
Ruling

1999 Ruling 9902623 - BUTTERFLY REORGANIZATION

We understand that to the best of your knowledge and that of XXXXXXXXXX, 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, or is under objection or appeal. ...
Miscellaneous severed letter

30 October 1992 Income Tax Severed Letter 2M0333A - Published Version of 1991 Canadian Tax Foundation

The Queen,61 the court concluded that the Income Tax Act, when read in conjunction with the Canada-US tax treaty62 and the Tax Convention Act,63 empowers the minister to issue a requirement for information sought by the US authorities in connection with their own taxation matters. 2) All requirements issued pursuant to subsection 231.2(1) are considered to be for a purpose relating to the administration or enforcement of the Act. ...
Ruling

2016 Ruling 2016-0626681R3 - Cross-border 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. ...
Ruling

2023 Ruling 2022-0957571R3 - Cross-Border Butterfly

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. ...
Miscellaneous severed letter

31 October 1990 Income Tax Severed Letter 3M05110 - APFF octobre 1990 - Questions et réponses

Utilities service connection expenses are eligible under paragraph 20(1)(ee) of the Act only if there is income from a business and if the conditions described in paragraphs 1 and 2 of Interpretation Bulletin IT-452 are met. ...
Ruling

2019 Ruling 2019-0794571R3 - Cross-Border 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 a previously filed tax return of the taxpayer or a person related to the taxpayer; (ii) being considered by a tax services office or taxation center in connection with a previously filed tax return of the taxpayer or a person related to the taxpayer; (iii) under objection by the taxpayer or a person related to the taxpayer; (iv) the subject of a current or completed court process involving the taxpayer or a person related to the taxpayer; or (v) the subject of an advance income ruling previously issued by the Income Tax Rulings Directorate. ...
Ruling

2021 Ruling 2020-0848061R3 - Sequential Butterfly

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 a person 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 a person related to the taxpayers; (iii) under objection by the taxpayers or a person related to the taxpayers; (iv) the subject of a current or completed court process involving the taxpayers or a person related to the taxpayers; or (v) the subject of an advance income ruling previously issued by the Income Tax Rulings Directorate. ...

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