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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 taxpayer issued debentures to raise money for use in making loans and paid finder's, fees in connection with the issuance of the debentures. ...

The trust will use the proceeds of partial notes receivable repayments to pay its income taxes arising from taxable dividends and taxable capital gains realized in connection with the disclosed transactions. 1) Does section 84.1 apply to the Proposed Transactions? ...

You advise that, to the best of the knowledge of XXXXXXXXXX, the General Partner and the Partnership, none of the issues described herein is being considered by a Tax Services Office or a Taxation Centre in connection with any tax return already filed or the subject of any notice of objection or is under appeal. ...

To the best of your knowledge and that of the taxpayers involved: a) none of the issues involved in the requested rulings is being considered by a Tax Services Office or a Taxation Centre in connection with a tax return already filed, and b) none of the issues involved in the requested rulings is the subject of any notice of objection or is under appeal. ...

DEPARTMENT'S POSITION As stated in paragraph 6 of IT-99R4, it is the Department's Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information practice to allow a taxpayer to deduct amounts expended in connection with legal and accounting fees incurred for advice and assistance in making representations after having been informed that the taxpayer's income or tax for a taxation year is to be revised, whether or not a formal notice of objection or appeal is subsequently filed. ...

We understand that to the best of your knowledge and that of the taxpayer involved, none of the issues described herein is: (i) dealt with in an earlier return of DC or a related person; (ii) being considered by a tax services office or a taxation centre in connection with a previously filed return of DC or a related person; (iii) under objection by DC 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 expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

To the best of your knowledge and that of the above-referenced taxpayer, none of the issues raised in the Rulings Request is: (i) in an earlier income tax return of the above-referenced taxpayer or a person related to that taxpayer; (ii) being considered by a tax services office or a taxation centre in connection with a previously filed tax return of the above-referenced taxpayer or a person related to that taxpayer; (iii) under objection by the above-referenced taxpayer or a person related to that taxpayer; (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. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...