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Additional Information To the best of your knowledge and that of the taxpayers involved, none of the issues involved with this ruling letter: (i) is under objection; (ii) is before the courts or, if a judgment has been issued, the time limit for appeal has not expired; (iii) is involved in an earlier return of one of the taxpayers or a related person; or (iv) is being considered by a tax services office or a taxation centre in connection with a tax return already filed by one of the taxpayers or a related person. ...

We understand that to the best of your knowledge, and that of the taxpayers involved, none of the matters considered in this ruling request are: (a) in an earlier return of the taxpayers or related persons; (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the taxpayers or related persons; (c) under objection by the taxpayers or related persons; (d) before the courts; or (e) the subject of a ruling previously issued by this Directorate to the taxpayers or related persons. ...

In connection with this method of determining the standby charge, you have referred to paragraph 21 of IT-83R3 which indicates an averaging method (as described therein) is appropriate where an employee and employer agree, and an employee is not assigned an automobile on a long-term basis. ...

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 XXXXXXXXXX, none of the issues in respect of which rulings are herein requested is currently under consideration by a tax services office or taxation centre in connection with a tax return or notice of objection already filed. ...

As a final comment, I would just mention that, in connection with a number of expenses described above, payments may be made to an agency for supplying an attendant while in other cases the attendant may be hired directly as an employee. ...

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. ...

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 role. ... Budget In connection with a ruling request, the Budget for the film will be reviewed. ...

Dodd Acting Director General 957-3495 Att: Blair Chisholm Banking, Insurance and Financial Products 912991 This is in reply to your T2003 dated October 28, 1991 requesting our comments on the October 11, 1991 submission by XXX, on behalf of the Bank XXX in connection with certain of their securities transactions. ... Per the Australian High Court at p. 608: "... and the real thing that has to be decided is what were the acts that were done in connection with the business and whether they amount to a trading which would cause the profits that accrued to be profits arising from a trade or business...... ...