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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. ...

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. ...

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. ...

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. ...

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. ...

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. ...

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. ...