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Technical Interpretation - Internal

10 November 2014 Internal T.I. 2014-0532801I7 - film or video production services tax credit

In Rulings document 2000-0025183 (XXXXXXXXXX, 2000), the following activities were not considered to detract from a conclusion that production services activities were the taxpayer's primary business on the basis that they were provided in connection with production services: XXXXXXXXXX. ...
Ruling

2013 Ruling 2013-0492831R3 - Trust to trust transfer of property

We understand that to the best of your knowledge, and that of the above taxpayer, none of the following issues involved in the ruling request is: (i) in an earlier tax return of the taxpayer or a related person, (ii) being considered by a tax services office or a tax centre in connection with a tax return already filed by 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 Directorate to the taxpayer or a related person. ...
Technical Interpretation - External

4 February 2015 External T.I. 2015-0565741E5 - Canadian-controlled private corporation

A agrees to indemnify Pubco, its directors and its employees (collectively, the "Indemnified Parties") in respect of claims and liabilities arising in connection with Pubco having served as trustee of the A Trust, including claims and liabilities of the A Trust for which any of the Indemnified Parties may be or become liable. 8. ...
Technical Interpretation - External

18 February 2015 External T.I. 2012-0466691E5 F - Revenu d’un Indien hors réserve

When considering as a whole the factors that may connect the business income to a reserve, it is our view that a sufficiently close connection does not exist to locate the income on a reserve. ...
Ruling

2014 Ruling 2013-0494711R3 - Public Body Ruling

We understand that, to the best of your knowledge and that of the taxpayer, none of the issues involved in the ruling request are: (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 expired; or (v) the subject of a ruling previously considered by the Directorate to the taxpayer or a related person. ...
Ruling

2016 Ruling 2016-0632001R3 - Replacement Property

To the best of your knowledge and that of the above-referenced taxpayer, none of the issues involved in this ruling is: i) dealt with in an earlier return of any of the above-referenced 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 above-referenced taxpayer or a related person, iii) under objection or appeal by the above-referenced taxpayers, 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 expired, or v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...
Technical Interpretation - External

1 June 2016 External T.I. 2015-0601211E5 - Mortgage loan from RRSP to make a shareholder loan

XXXXXXXXXX: Re: Proceeds of a Mortgage Loan from an RRSP used to make a Shareholder Loan We are writing in reply to your correspondence of July 28, 2015 in connection with the use of the proceeds of a mortgage loan from a registered retirement savings plan (RRSP). ...
Ruling

2012 Ruling 2010-0367401R3 - Variation of trust

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 tax return of the taxpayer or a related person; (ii) being considered by a tax services office or a tax centre in connection with a tax return already filed by 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 Directorate to the taxpayer or a related person. ...
Ruling

2016 Ruling 2015-0606771R3 - Disclaimer of trust interest

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 tax return of the taxpayer or a related person; (ii) being considered by a tax services office or a tax centre in connection with a tax return already filed by 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 Directorate to the taxpayer or a related person. ...
Ruling

2016 Ruling 2015-0593841R3 - Sale of XXXXXXXXXX Club

To the best of your knowledge and that of the taxpayer, none of the issues involved in the ruling request are: 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 expired; or v) the subject of a ruling previously issued by this Directorate to the taxpayer or a related person. ...

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