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To the best of your knowledge and that of the above-referenced taxpayer, none of the issues involved in this ruling is: (a) in an earlier return of the above-referenced taxpayer 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 above-referenced taxpayer or a related person; (c) under objection by the above-referenced taxpayer or a related person; (d) before the courts; or (e) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (a) dealt with in an earlier return of the taxpayers or related persons; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or related persons; (c) under objection by one or any of the taxpayers or related persons; (d) the subject of a ruling previously issued by the Income Tax Rulings Directorate; or (e) before the courts. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in this ruling request is: (i) in a previously filed tax return of the taxpayers or persons related to the taxpayers; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or persons related to the taxpayers; (iii) under objection by the taxpayers or persons related to the taxpayers; (iv) the subject of a current or completed court process involving the taxpayers or persons related to the taxpayers; or (v) the subject of an advance income ruling previously issued by the Income Tax Rulings Directorate. ...

To the best of your knowledge and that of the taxpayers involved: (i)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 (ii)none of the issues involved in the requested rulings is the subject of any notice of objection or is under appeal. ...

To the best of your knowledge, and that of the parties to this ruling, none of the issues contained in this advance income tax ruling is being considered by a Tax Services Office and/or a Taxation Centre in connection with an income tax return previously filed and none of the issues contained herein is under objection or appeal. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein: (i) is in an earlier return of the taxpayer or a related person; (ii) is 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) is under objection by the taxpayer or a related person; or (iv) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...

To the best of your knowledge, and that of the parties to this ruling, none of the issues contained in this advance income tax ruling: 1. is in an earlier return of the taxpayer or a related person, 2. is being considered by a tax services office or a taxation centre in connection with a previously filed tax return of the taxpayer or a related person, 3. is under objection by the taxpayer or related person, 4. is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired, or 5. is the subject of a ruling previously issued by the Directorate. ...

--an outlay or expense to the extent that it was made or incurred by a corporation in a taxation year for the purpose of gaining or producing income from a personal services business (within the meaning assigned by paragraph 125(7)(d)), other than (i)     the salary, wages or other remuneration paid in the year to an incorporated employee of the corporation, (ii)     the cost to the corporation of any benefit or allowance provided to an incorporated employee in the year, (iii)     any amount expended by the corporation in connection with the selling of property or the negotiating of contracts by the corporation if the amount would have been deductible in computing the income of an incorporated employee for a taxation year from an office or employment if the amount had been expended by the incorporated employee under a contract of employment that required him to pay the amount, and (iv)     any amount paid by the corporation in the year as or on account of legal expenses incurred by it in collecting amounts owing to it on account of services rendered that would, if the income of the corporation were from a business other than a personal services business, be deductible in computing its income; Interpretation Bulletins: Secondary--IT-73R4; IT-168R3. 61(4)(c) "qualifying payment" means a single payment made before November 13, 1981 (or made on or after November 13, 1981 pursuant to an agreement in writing entered into before that date to make such a payment in respect of his 1981 taxation year, or pursuant to an arrangement in writing made before that date to have funds withheld before 1982 from any of the individual's remuneration described in paragraph (1)(b) earned or received before November 13, 1981 and paid by or on behalf of the individual). 61(1) In computing the income for a taxation year of an individual resident in Canada, there may be deducted an amount equal to the lesser of (a)     such amount as he may claim, not exceeding the aggregate of amounts each of which is a single payment (i)     made by him in the year or within 60 days after the end of the year as consideration for an income-averaging annuity contract of the individual, and (ii)     in respect of which no amount has been deducted in computing his income for the immediately preceding taxation year, and (b)     the amount, if any, by which the aggregate of (i)     the remainder obtained when the aggregate of the amounts deductible in computing the taxpayer's income for the year by virtue of paragraphs 60(j), (k) and (l) is deducted from the aggregate of amounts described in subsection (2) in respect of the individual for the year, (ii)     the amount, if any, by which the amount determined under paragraph 3(b) in respect of the individual for the year exceeds the aggregate of amounts each of which is an allowable business investment loss of the individual for the year, (iii)     the individual's income for the year from the production of a literary, dramatic, musical or artistic work, (iv)     the individual's income for the year from his activities as an athlete, a musician or a public entertainer such as a theatre, motion picture, radio or television artist, and (iv.1) the amount, if any, by which the amount included in computing the income of the individual for the year by virtue of section 59 exceeds the aggregate of amounts deducted in computing his income for the year under sections 64, 66, 66.1, 66.2 and 66.4 and under section 29 of the Income Tax Application Rules, 1971, exceeds (v)     the aggregate of amounts each of which is the annual annuity amount of the individual in respect of an income-averaging annuity contract in respect of the consideration for which any amount has been deducted under this subsection in computing his income for the year. 63(3)(b) "Earned income" of a taxpayer means the aggregate of (i)     all salaries, wages and other remuneration, including gratuities, received by him in respect of, in the course of, or by virtue of offices and employments, and all amounts included in computing his income by virtue of sections 6 and 7, (ii)     amounts included in computing his income by virtue of paragraph 56(1)(m), (n) or (o), and (iii)     his incomes from all businesses carried on either alone or as a partner actively engaged in the business; 78(4) Where an amount in respect of a taxpayer's expense that is a superannuation or pension benefit, a retiring allowance, salary, wages or other remuneration (other than reasonable vacation or holiday pay or a deferred amount under a salary deferral arrangement) in respect of an office or employment is unpaid on the day that is 180 days after the end of the taxation year in which the expense was incurred, for the purposes of this Act other than this subsection, the amount shall be deemed not to have been incurred as an expense in the year and shall be deemed to be incurred as an expense in the taxation year in which the amount is paid. 81(2) Where an elected member of a provincial legislative assembly has, under an Act of the provincial legislature, been paid an allowance in a taxation year for expenses incident to the discharge of his duties as a member, the allowance shall not be included in computing his income for the year unless it exceeds 1/2 of the maximum fixed amount provided by law as payable to him by way of salary, indemnity and other remuneration as a member in respect of attendance at a session of the legislature, in which event there shall be included in computing his income for the year only the amount by which the allowance exceeds 1/2 of that maximum fixed amount. 153(1) Every person paying at any time in a taxation year (a)     salary or wages or other remuneration, (b)     a superannuation or pension benefit, (c)     a retiring allowance, (d)     a death benefit, (d.1)      an amount as a benefit under the Unemployment Insurance Act, 1971, (e)     an amount as a benefit under a supplementary unemployment benefit plan, (f)     an annuity payment or a payment in full or partial commutation of an annuity, (g)     fees, commissions or other amounts for services, (h)     a payment under a deferred profit sharing plan or a plan referred to in section 147 as a revoked plan, (i)     a training allowance under the National Training Act, (j)     a payment out of or under a registered retirement savings plan or a plan referred to in subsection 146(12) as an "amended plan", (k)     an amount as, on account or in lieu of payment of, or in satisfaction of, proceeds of the surrender, cancellation or redemption of an income-averaging annuity contract, (l)     a payment out of or under a registered retirement income fund or a fund referred to in subsection 146.3(11) as an "amended fund", (m)     an amount as a benefit under the Labour Adjustment Benefits Act, (m.1)     an income assistance payment made pursuant to an agreement under section 5 of the Department of Labour Act, (n)     one or more amounts to an individual who has elected for the year in prescribed form in respect of all such amounts, (o)     an amount described in paragraph 115(2)(c.1), (p)     a contribution under a retirement compensation arrangement, (q)     an amount as a distribution to one or more persons out of or under a retirement compensation arrangement, or (r)     an amount on account of the purchase price of an interest in a retirement compensation arrangement shall deduct or withhold therefrom such amount as may be determined in accordance with prescribed rules and shall, at such time as may be prescribed, remit that amount to the Receiver General on account of the payee's tax for the year under this Part or Part XI.3, as the case may be. ...

To the best of your knowledge and that of the Applicants involved, none of the issues contained herein: (i) is in an earlier tax return of any of the Applicants or a related person; (ii) is being considered by a tax services office or taxation centre in connection with a previously filed tax return of any of the Applicants or a related person; (iii) is under objection by any Applicant or a related person; (iv) is before the Courts or, if a judgement has been issued, the time limit for appeal to a higher Court has expired; or (v) is the subject of an advance income tax ruling previously issued by the Income Tax Rulings Directorate XXXXXXXXXX. ...

To the best of your knowledge, and that of the taxpayer involved, none of the issues contained herein is: (a) dealt with in an earlier return of the taxpayer 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 taxpayer or a related person; (c) under objection by one or any of the taxpayer or a related person; (d) the subject of a ruling previously issued by the Income Tax Rulings Directorate; or (e) before the courts. ...