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However, this position applies only where the corporation pays premiums equal to the annual increase in the policy's cash surrender value and the corporation is entitled to the cash surrender value of the policy on its termination or to a portion of the amount payable under the original policy on death equal to its cash surrender value immediately before death as well as to the dividends that arise in connection with the policy (or anything substituted therefore). ...

To the best of your knowledge and that of the taxpayers involved, none of the issues involved in this ruling (i) is in an earlier return of the taxpayers 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 taxpayers or a related person, (iii) is under objection by the taxpayers or a related person, (iv) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expi red, (v) is the subject of a ruling previously issued by the Directorate. ... Pursuant to a production services agreement, THC will engage Creditco to perform $XXXXXXXXXX of production services in connection with the production of the Film. ... Pursuant to a production services agreement, THC will engage the Production Partnership to provide to THC $XXXXXXXXXX of production services in connection with the Film. ...

To the best of your knowledge and that of the taxpayers involved in this ruling, none of the issues contained in this ruling is being considered by any office of Revenue Canada in connection with an income tax return previously filed and none of the issues contained herein is the subject of a notice of objection or is under appeal. ... XXXXXXXXXX carries on in Canada the business of XXXXXXXXXX 4.Each of XXXXXXXXXX is a "principal-business corporation", within the meaning of subsection 66(15) of the Act, whose "taxation year" for purposes of the Act ends on XXXXXXXXXX 5.As described in more detail in paragraphs 42.2 through 42.4 of the Ruling, in connection with the acquisition by XXXXXXXXXX of its interest in XXXXXXXXXX 6. ... However, it is also our opinion that, provided that there are no statements or representations, of the type referred to in the definition of "tax shelter" contained in subsection 237.1(1) of the Act, as amended, made or proposed to be made by any person in connection with the shares of Finco to be acquired by XXXXXXXXXX, those shares will not be a "tax shelter" within that definition. ...

We also acknowledge the information provided in subsequent correspondence, in a meeting and during our various telephone conversations in connection with your request (XXXXXXXXXX). We understand that to the best of your knowledge and that of the taxpayers involved: i) none of the issues involved in the requested ruling is being considered by any District Tax Services Office or Taxation Centre of the Department in connection with a tax return already filed, and ii) none of the issues involved in the requested ruling is the subject of any notice of objection or is under appeal. ... COMMENTS a) Except as expressly stated herein, nothing in this ruling should be construed as implying that Revenue Canada Customs, Excise and Taxation has accepted, approved or confirmed any income tax implications in connection with the facts or proposed transactions referred to herein. b) Nothing in this ruling should be construed as implying that Revenue Canada Customs, Excise and Taxation has determined, acknowledged or otherwise concluded that the amendments to the Existing Bond Indenture or the Debenture Indenture will not constitute a disposition for purposes of the Act. ...

Savage, [[1983] C.T.C. 393] 83 DTC 5409, as a phrase with the widest possible scope intended to convey some connection between two related subject matters. ... The fact that a corporation, carrying on an active business and holding certain property (i.e. investments) unrelated to the business, uses the income from property in connection with the operation of the active business does not mean that the property is "incident to or pertains to" the active business. ...

Expenses You comment that a lender will normally require the borrower to pay or reimburse the lender for the reasonable fees and expenses incurred by the lender (including reasonable counsels' fees) in connection with the preparation of the loan documentation and the making of the loan, including the perfection of security interests, any subsequent modifications to any terms of the loan and costs and expenses in connection with the enforcement of the loan obligations. ...

However, the following facts are usually set out in connection with requests for advance rulings: (i) the name of the producer, who must be a Canadian; (ii) the names of any corporations set up by the producer to produce the film, whether or not they are Canadian, and the names and nationalities of the shareholders and directors; (iii) the involvement of non-Canadians and their explicit roles. ... In connection with a ruling request, the budget for the film will be reviewed. ...

In this connection the judgement of latham C. J. (1944), 69 C. L. R. 235, at page 240-241, is particularly relevant. ... Paragraph 212(1)(d): Sale of Intangibles In connection with subparagraph 212(1)(d)(i), the obiter observation of Thurlow J. ... The use of the word rentals' in connection with the licensing of intangibles therefore perhaps inevitable leads to inapposite results. ...

In the particular case, where the individual exercises his stock option after he has ceased to be an employee, he will be taxable in Canada as though he were still an employee of CANCO on any employee stock option benefits which arise in connection with that employment pursuant to subsections 7(1) and (4) of the Income Tax Act (the "Act"). ...

To the best of your knowledge and that of the taxpayers involved, none of the issues involved in this request is: a. in an earlier 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; d. before the courts; or e. the subject of a ruling previously issued by this Directorate; DEFINITIONS In this letter, the following terms or expressions have the meanings specified: a) "Act" means the Income Tax Act, R.S.C. 1985 c.1 (5th supp) as amended to the date hereof. ...