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., a mortgage prepayment penalty) is incurred in connection with the disposition of a capital property, the cost of the fine or penalty is taken into account under subsection 40(1) for the purposes of calculating any gain or loss on that disposition. ...

We understand that, to the best of your knowledge and that of the taxpayer named above, none of the issues involved in the ruling request is: (i) involved 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) before the courts; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate involving the taxpayer or a related person. ...

We understand that, to the best of your knowledge and that of the taxpayers named above, none of the issues involved in the ruling request is: (i) involved 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) before the courts; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate involving the taxpayer or a related person. ...

You have advised us that to the best of your knowledge and that of the taxpayers involved, none of the issues involved in this rulings are: (i) dealt with in an earlier return of the taxpayers or a related person; (ii) being considered by a Tax Services Office or Taxation Centre in connection with a previously filed tax return of any of the taxpayers or a related person; (iii) under objection by any of the taxpayers or a related person; (iv) before the courts or, if a judgement has been issued, the time limit for an appeal to a higher court has expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

We understand that, to the best of your knowledge and that of the taxpayer, none of the issues involved in the ruling request is: (i) 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) before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has not yet expired. ...

We understand that, to the best of your knowledge and that of the above-referenced Corporation, none of the issues involved in the ruling request is: (i) in an earlier return of the Corporation or a related person; (ii) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Corporation or a related person; (iii) under objection by the Corporation or a related person; (iv) before the courts; nor, (v) the subject of a ruling previously considered by the Directorate. ...

Cases involving the deductibility of legal fees incurred to establish a right to a promotion or a raise or where the claimant is seeking financial compensation in connection with allegations of unlawful or wrongful acts by an employer remain distinguishable. ...

We understand that, to the best of your knowledge, and that of the taxpayer, none of the issues described herein is: a) 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; b) under objection by the taxpayer or a related person; nor, c) before the Courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in this Ruling letter: (i) is in an earlier return of the above-noted taxpayers or a related person; (ii) is being considered by a Tax Services Office or Tax Centre in connection with a previously filed tax return of the above-noted taxpayers or a related person; (iii) is under objection by the above-noted 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 is the subject of a Ruling previously issued by the Income Tax Rulings Directorate. ...

An RCA strip occurs where there has been a reduction in value of the property held in connection with the RCA as part of a series of transactions or events one of the main purposes of which was to enable a specified beneficiary (or a person or partnership who does not deal at arm's length with a specified beneficiary) to obtain a benefit in respect of the RCA property or as a result of that reduction, and there has been no related income inclusion. ...