Search - connection

Results 5441 - 5450 of 7793 for connection
Ruling

2019 Ruling 2018-0781971R3 - Loss Consolidation

We understand that, to the best of your knowledge and that of the Taxpayers involved, none of the proposed transactions or issues involved in this Ruling request are the same or substantially similar to transactions or issues that are: (i) in a previously filed tax return of the Taxpayers or a related person and: a. being considered by the CRA in connection with such return; b. under objection by the Taxpayers or a related person; or the subject of a current or completed court process involving the Taxpayers or a related person; or (ii) the subject of a Ruling request previously considered by the Income Tax Rulings Directorate. ...
Ruling

2017 Ruling 2017-0711911R3 - loss consolidation ruling

To the best of your knowledge and that of the Taxpayers, none of the issues involved in the ruling request is: i. in a previously filed tax return of any of the Taxpayers or a related person; ii. being considered by a tax services office or a tax 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. the subject of a current or completed court process involving the Taxpayers or a related person; or v. the subject of a ruling request previously considered by the Directorate. ...
Ruling

2019 Ruling 2018-0782751R3 - Standard Loss Consolidation

To the best of your knowledge and that of the taxpayers involved, none of the proposed transactions or issues involved in this Ruling request are the same as or substantially similar to transactions or issues that are: i. in a previously filed tax return of the taxpayers or a related person and: A. being considered by the CRA in connection with such return; B. under objection by the taxpayers or a related person; or C. the subject of a current or completed court process involving the taxpayers or a related person; or ii. the subject of a Ruling request previously considered by the Income Tax Rulings Directorate. ...
Ruling

2020 Ruling 2020-0839401R3 - Post-mortem Pipeline

We understand that to the best of your knowledge and that of the Taxpayers, none of the proposed transactions or issues involved in this Ruling are the same as or substantially similar to transactions or issues that are: (a) in a previously filed return of the Taxpayers or a related person; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the Taxpayers or a related person; (c) under objection by the Taxpayers or a related person; (d) the subject of a current or completed court process involving the Taxpayers or a related person; or (e) the subject of a ruling previously considered by the Income Tax Rulings Directorate in relation to the Taxpayers or a related person. ...
Ruling

2020 Ruling 2019-0835141R3 - Loss consolidation arrangement

To the best of your knowledge and that of the taxpayers involved, none of the proposed transactions or issues involved in this Ruling request are the same as or substantially similar to transactions or issues that are: i. in a previously filed tax return of the taxpayers or a related person and: A. being considered by the CRA in connection with such return; B. under objection by the taxpayers or a related person; or C. the subject of a current or completed court process involving the taxpayers or a related person; or ii. the subject of a Ruling request previously considered by the Income Tax Rulings Directorate. ...
Ruling

2020 Ruling 2020-0865971R3 - Loss consolidation arrangement

To the best of your knowledge and that of the taxpayers involved, none of the proposed transactions or issues involved in this Ruling request are the same as or substantially similar to transactions or issues that are: i. in a previously filed tax return of the taxpayers or a related person and: A. being considered by the CRA in connection with such return; B. under objection by the taxpayers or a related person; or C. the subject of a current or completed court process involving the taxpayers or a related person; or ii. the subject of a Ruling request previously considered by the Income Tax Rulings Directorate. ...
Ruling

2015 Ruling 2015-0573201R3 - Qualifying environmental trust

To the best of your knowledge and that of the taxpayers named above, none of the issues involved in this advance income tax ruling is: in an earlier return of the taxpayers or any related person; being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or any related person; under objection by the taxpayers or any related person; before the courts; or the subject of a ruling previously considered by the Income Tax Rulings Directorate in respect of the taxpayers or any related person. ...
Ruling

2015 Ruling 2015-0573211R3 - Qualifying environmental trust

To the best of your knowledge and that of the taxpayers named above, none of the issues involved in this advance income tax ruling is: in an earlier return of the taxpayers or any related person; being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or any related person;under objection by the taxpayers or any related person; before the courts; or the subject of a ruling previously considered by the Income Tax Rulings Directorate in respect of the taxpayers or any related person. ...
Ruling

2015 Ruling 2015-0573231R3 - Qualifying environmental trust

To the best of your knowledge and that of the taxpayers named above, none of the issues involved in this advance income tax ruling is: in an earlier return of the taxpayers or any related person; being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or any related person; under objection by the taxpayers or any related person; before the courts; or the subject of a ruling previously considered by the Income Tax Rulings Directorate in respect of the taxpayers or any related person. ...
Ruling

2015 Ruling 2015-0573191R3 - Qualifying environmental trust

To the best of your knowledge and that of the taxpayers named above, none of the issues involved in this advance income tax ruling is: in an earlier return of the taxpayers or any related person; being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or any related person; under objection by the taxpayers or any related person; before the courts; or the subject of a ruling previously considered by the Income Tax Rulings Directorate in respect of the taxpayers or any related person. ...

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