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Where all of the relevant facts pertaining to a particular situation establish that the feasibility study cannot qualify for treatment as CEE, the costs thereof would be accorded the appropriate treatment described at paragraphs 4 and 5 of Interpretation Bulletin IT-475 and question 28 of the 1986 Revenue Canada Round Table: Normally, a feasibility study undertaken to determine whether or not a particular course of action is desirable in connection with an existing business is considered to be a current expenditure. ...

Pursuant to comments in your letter, we have also considered certain comments made in the tax service entitled "Access to Canadian Income Tax" which, in connection with a letter dated May 16, 1986 issued by this Department, stated "that where benefits were being received or there was an entitlement to benefits from a claim made in respect of an event that took place prior to the date of conversion to an employee-pay-all plan, there would be no change in the tax status of these benefits. ...

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; 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. ...

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. ...

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: i. in a previously filed return of the Taxpayers or a related person and; A. 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; B. under objection by the Taxpayers or a related person; C. the subject of a current or completed court process involving the Taxpayers or a related person; or ii. the subject of an advance income tax ruling previously considered by the Income Tax Rulings Directorate in relation to the Taxpayers or a related person. ...

The ordinary meaning of the words “maintain,” “modify,” or “transform”, when considered in light of their context, appear to suggest that any costs incurred in connection with these types of activities would be costs that are incurred subsequent to the acquisition of a particular property. ...

XXXXXXXXXX 2023-096155 XXXXXXXXXX, 2023 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request XXXXXXXXXX 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; c. the subject of a current or completed court process involving the Taxpayers or a related person; or (ii) except as provided herein, the subject of a ruling request previously considered by the Income Tax Rulings Directorate. ...

The tax account numbers, Tax Services Offices, and Tax Centres of the taxpayers involved are as follows: XXXXXXXXXX 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 tax return of the taxpayer or a related person and: i. being considered by the CRA in connection with such return; ii. under objection by the taxpayer or a related person; or iii. the subject of a current or completed court process involving the taxpayer or a related person; or b) the subject of a ruling request previously considered by the Income Tax Rulings Directorate. ...

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: i. in a previously filed return of the Taxpayers or a related person and; A. 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; B. under objection by the Taxpayers or a related person; C. the subject of a current or completed court process involving the Taxpayers or a related person; or ii. the subject of an advance income tax ruling previously considered by the Income Tax Rulings Directorate in relation to the Taxpayers or a related person. ...

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. ...