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To the best of your knowledge and that of the Company, none of the issues contained herein: (i) is in an earlier tax return of the Company 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 Company or a related person; (iii) is under objection by the Company 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 to the Company or a related person. ...

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

We understand that, to the best of your knowledge and that of the Companies, none of the issues involved in the ruling request is: in an earlier return of the Companies or a related person, being considered by a tax services office or tax centre in connection with a previously-filed tax return of the Companies or a related person, under objection by the Companies or a related person, before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired, nor the subject of a ruling previously issued by the Directorate other than the Ruling and Supplemental Ruling. ...

You have advised us that to the best of your knowledge and that of the taxpayer involved none of the issues involved in this ruling request: (a) is in an earlier return of the taxpayer or a related person; (b) is being considered by a tax services office ("TSO") or taxation centre ("TC") in connection with a previously filed tax return of the taxpayer or a related person; (c) is under objection by the taxpayer or a related person; (d) is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired; or (e) is the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

Guideline 4 requires a) that the employer is resident on a reserve; b) that the employer is an Indian band which has a reserve, or a tribal council representing one or more Indian bands which have reserves, or an Indian organization controlled by one or more such bands or tribal councils, if the organization is dedicated exclusively to the social, cultural, educational, or economic development of Indians who for the most part live on reserves; and c) that the duties of the employment are in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserves. ...

Wording of 8(1)(h.1)(ii) In connection with the above two situations, it was brought to our attention that the wording in 8(1)(h.1)(ii) in the DeBoo version of the Income Tax Act was slightly different than the CCH version. ...

In connection with the adverse decision in the Nomad case, Technical Publications Division referred the matter to the Department of Finance ("Finance") on January 7, 1991 for tax policy consideration. ...

If, in fact, that cargo handling operation had developed to a stage where it was beyond any reasonable requirements of the company's own ships, it would seem appropriate to treat it as a separate business and, in the context of the question at hand, to exclude those revenues arising in connection with cargo services provided to the other shipowners. ...

Where the expense qualifies as CEE, we agree that a taxpayer has the choice of claiming such an expense as either CEE or a utility service connection expense under paragraph 20(1)(ee). ...

Wording of 8(1)(h.1(ii) In connection with the above two situations, it was brought to our attention that the wording in 8(1)(h.1)(ii) in the DeBoo version of the Income Tax Act was slightly different than the CCH version. ...