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

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is being considered by a tax services office or a taxation center in connection with any tax return already filed and none of the issues is under objection or appeal. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in the ruling request is: i. in an earlier return of the company or a related person; ii. being considered by a tax services office or a taxation centre in connection with a tax return already filed by the company or a related person; iii. under objection by the company or a related person; iv. before the courts or, if a judgment has been issue, the time limit for appeal to a higher court has not expired; and v. the subject of a ruling previously issued by the Directorate. ...

To the best of your knowledge and the knowledge of the Corporation, none of the issues involved in this request for an advance income tax ruling: (a) is in an earlier return of the Corporation or the Individual or of a person related to either of them; (b) is being considered by a tax services office or tax centre in connection with a previously-filed return of the Corporation or the Individual or of a person related to either of them; (c) is under objection by the Corporation or the Individual or by a person related to either of them; (d) is before the courts; or (e) is the subject of a ruling previously issued by the Income Tax Rulings Directorate to the Corporation or the Individual. ...

OTHER INFORMATION To the best of your knowledge and that of the Company, none of the issues involved in this ruling request are: a) in an earlier return of the Company 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, c) the subject matter of any notice of objection filed pursuant to the Act by the Company or a related person, or d) before the courts. ...

OTHER INFORMATION To the best of your knowledge and that of the Employer, none of the issues involved in this ruling are: a) in an earlier return of the Employer, an Employee, 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 Employer, an Employee, or a related person; c) the subject matter of any notice of objection filed pursuant to the Act by the Employer, an Employee, or a related person; d) before the courts; or e) the subject of an advance income tax ruling previously issued by the Directorate. ...

To the best of your knowledge and the knowledge of the Employer, none of the issues involved in this request for an advance income tax ruling: (a) is in an earlier return of the Employer, a Participant or of a person related to either of them; (b) is being considered by a tax services office or tax centre in connection with a previously-filed return of the Employer, a Participant or of a person related to either of them; (c) is under objection by the Employer, a Participant or by a person related to either of them; (d) is before the courts; or (e) is the subject of a ruling previously issued by the Income Tax Rulings and Interpretations Directorate to the Employer or a Participant. ...

" In general terms, the conditions set out in paragraph 149(1)(l) of the Act with which a club, society or association must comply in order to qualify for exemption as a non-profit organization are as follows: (a) it must not, in the opinion of the Minister, be a charity; (b) it must be organized exclusively for social welfare, civic improvement, pleasure, recreation or any other purpose except profit; (c) it must in fact be operated exclusively for the same purpose in (b) for which it was organized or for any of the other purposes mentioned in (b); and (d) no part of its income may be paid, payable or otherwise made available for the personal benefit of any proprietor, member or shareholder, except in connection with the promotion of amateur athletics in Canada. ...

In connection with this issue, Individual A has indicated that Individual C reported the Maintenance as income in 1996 and 1997 under the relevant provisions of the Act. ...

In addition the education amount is not available, in any case, when employees have their eligible tuition fees paid for or reimbursed by their employer or when they receive remuneration while taking training in connection with their duties of employment. ...