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We understand that, to the best of your knowledge, none of the issues raised in this ruling is being considered by a Taxation Services Office or Taxation Centre in connection with an income tax return already filed, is the subject of any notice of objection or is under appeal. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues involved with this request: a) is involved in an earlier return of the taxpayer or a related person, b) is being considered by a tax services office or a taxation centre in connection with a tax return already filed by the taxpayer or a related person, c) is under objection, or d) is before the courts or, if a judgement has been issued, the time limit for appeal has not expired. 2. ...

To the best of your knowledge, and that of the taxpayer involved, none of the issues contained herein is: (i) dealt with in an earlier return of the 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 taxpayer or a related person; (iii) under objection by the taxpayer or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...

We understand that to the best of your knowledge and that of the taxpayers involved none of the issues involved in this ruling request are being considered by a Tax Services Office or a Taxation Centre in connection with any tax return already filed, and none of the issues involved in the requested rulings is the subject of any notice of objection or is under appeal. ...

M.N.R. (83 DTC 278), le tribunal offre certains commentaires sur cette expression en mentionnant à la page 281 ce qui suit: "In my view, these kinds of expenses embrace only those related directly to the sale of the former home, and not all the expenses or costs incurred in connection with the sale of his old residence. ...

To the best of your knowledge, none of the issues involved in this ruling request are: a) in an earlier return of the Company or a related person or an Annuitant or a related person, b) being considered by any tax services office or tax centre in connection with a previously filed tax return of the Company or a related person or an Annuitant or a related person, c) the subject matter of any notice of objection filed pursuant to the Act by the Company or a related person or an Annuitant or a related person, d) before the courts, or e) the subject of a ruling previously issued by this Directorate. ...

In connection with this, it is our understanding that, in many CSs such as the United States, the taxation is based on the gross capital gains. ...

To the best of your knowledge, and that of the taxpayer involved, none of the issues contained herein is: (i) dealt with in an earlier return of the 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 taxpayer or a related person; (iii) under objection by the taxpayer or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings Directorate; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...

We understand that to the best of your knowledge, and that of the taxpayers involved, none of the matters considered in this ruling request are: a) in an earlier return of the taxpayers or related persons; b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the taxpayers or related persons; c) under objection by the taxpayers or related persons; d) before the courts; or e) the subject of a ruling previously issued by this Directorate to the taxpayers or related persons. ...

To the best of your knowledge, none of the issues involved in this ruling: i) are in an earlier return of the Company, a person related to the Company or the Executive; ii) are being considered by a tax services office or tax centre in connection with a previously filed tax return of the Company, a person related to the Company or the Executive; iii) are under objection by the Company, a person related to the Company or the Executive and; iv) are before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired 8. ...