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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 the above-referred taxpayer or a related person; (ii) being considered by a tax services office or a taxation centre in connection with a previously filed return of the above-referred taxpayer or a related person; (iii) under objection by the above-referred taxpayer 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. ... In connection with the winding-up of DC, DC will: (a) assign and distribute the TC1 Redemption Note to TC1; (b) assign and distribute the TC2 Redemption Note to TC2; (c) assign and distribute the TC3 Redemption Note to TC3; (d) assign and distribute the TC4 Redemption Note TC4; and (e) distribute an amount of assets to C Trust equal to the Retraction Price and FMV of the DC "A" Shares. 28. ... 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 Old Pubco, none of the issues involved in this advance rulings request is: (i) in an earlier return of Old Pubco or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of Old Pubco or a related person; (iii) under objection by Old Pubco 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 expired; or (v) the subject of rulings previously issued by the Income Tax Rulings Directorate. ... Old Pubco is a publicly traded corporation that was formed in connection with XXXXXXXXXX. 3. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

Finally, Audit argues that an acceptance of Canco's position would result in the avoidance of the Foreign Accrual Property Income ("FAPI") regime any time a tenuous connection existed between the interest income earned by one affiliate, and the current or future active business of another affiliate. ... In respect of the words "directly related to", as used in 95(2)(a)(i)(A), it is our opinion that this must be interpreted to mean a more circumscribed amount of connection than would otherwise be indicated by the phrases "related to" or "in relation to. ... For instance, in describing the connection that is required under 95(2)(a)(i), Finance stated that: "The activities resulting in the income from property must be dependent upon and would not have taken place but for the active business activities taking place. ...

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 return of the taxpayers or a related person; (ii) 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) under objection by the taxpayers 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 expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate of the CRA. ... In connection with the First Amalgamation described in Paragraph 33, Amalco1 did not file a designation under paragraph 88(1)(d) in its federal return of income for its taxation year that commenced at the time of the First Amalgamation and ended immediately before the Second Amalgamation. In connection with the Second Amalgamation described in Paragraph 34, in Amalco2's federal return of income for its taxation year that commenced at the time of the Second Amalgamation and ended on XXXXXXXXXX, Amalco2 filed a designation pursuant to paragraph 88(1)(d) to increase, within the limits described in paragraph 88(1)(d), the cost to Amalco2 of the Subco1 shares first, then the shares of other foreign affiliates and finally, other capital property (other than any ineligible property as described in paragraph 88(1)(c)) that Amalco1 owned without interruption at and since the time XXXXXXXXXX ULC [Canco1] last acquired control of Amalco1 and that became property of Amalco2 by virtue of the Second Amalgamation as described in Paragraph 34. ...

We understand that to the best of your knowledge and that of the taxpayers involved, none of the issues described herein is: (i) dealt with in an earlier return of the taxpayers or a person related to any of 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 a person related to any of the taxpayers; (iii) under objection by the taxpayers or a person related to any of the taxpayers; (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. ... The agreed amount in respect of each such eligible property will be as follows: (a) in the case of capital property (other than depreciable property of a prescribed class), an amount equal to the lesser of the amounts described in subparagraphs 85(1)(c.1)(i) and (ii); (b) in the case of depreciable property of a prescribed class, if any, an amount not less than the least of the amounts described in subparagraphs 85(1)(e)(i), (ii) and (iii); (c) in the case of eligible capital property in respect of a business of DC, an amount not less than the least of the amounts described in subparagraphs 85(1)(d)(i), (ii) and (iii); and (d) in the case of XXXXXXXXXX owned in connection with the XXXXXXXXXX business of DC, an amount determined in accordance with the formula set out in paragraph 85(1)(c.2). ... In connection with the winding-up of DC, DC will distribute all of its assets to TC1 and TC2 in accordance with their shareholdings. ...

In the following cases, the courts have confirmed that whether an activity constitutes hedging depends on sufficient inter-connection or integration with the underlying transaction: Salada Foods Ltd. v Her Majesty the Queen, 74 DTC 6171(FCTD) Minister of Finance (Ontario) v Placer Dome Canada Limited, 2006 DTC 6532 (SCC) Echo Bay Mines Ltd. v Her Majesty the Queen, 92 DTC 6437 (FCTD) Degree of linkage between a derivative financial instrument and an underlying transaction Consistent with this general principle, the courts have held that for financial instruments to constitute a hedge there must be sufficient linkage with the underlying transaction. ... Placer Dome Canada Limited, 2006 SCC 20) have confirmed that whether an activity constitutes hedging depends on sufficient inter-connection or integration with the underlying transaction. ... Therefore the conclusion that paragraph 20(1)(e) applied necessarily implied that the Court had characterized the forward contracts as being otherwise non-deductible, presumably because they were capital in nature given their connection to the borrowing. ...

To the best of your knowledge, and that of the taxpayer involved, none of the issues involved in this ruling request is (i) in an earlier return of the taxpayer or a related person; (ii) 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) under objection by the taxpayer 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 expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... The DC Common Shares and the DC Special Shares will not constitute taxable Canadian property and, therefore, no notice to the Minister under section 116 will be sent in connection with the dispositions of the DC Common Shares and the DC Special Shares by Foreign Pubco. 22. ... It is not anticipated that DC will transfer any of these long-term liabilities to TC in connection with the transfer of property described in Paragraph 26. ...

To the best of your knowledge and that of the taxpayers (or their officers where the taxpayer is a corporation) involved, none of the issues involved in this ruling request is: (a) in an earlier return of any of the taxpayers or any related person; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of any of the taxpayers or any related person; (c) under objection by any of the taxpayers or any related person; (d) before the courts; or (e) subject to advance income tax ruling 2002-013633, dated XXXXXXXXXX, 2002, the subject of any other ruling previously considered by the Directorate. ... A is a non-resident of Canada who is a resident of the United States and manages the business operations carried on in connection with the Asset and the Realty leased and managed by Leaseco. ... In connection with this refinancing the lenders agreed to permit the implementation of the Proposed Transactions. ...

We also acknowledge the information provided in your letters and e-mails of XXXXXXXXXX, and during our various telephone conversations in connection with your ruling request (XXXXXXXXXX). We understand that to the best of your knowledge and that of the taxpayers involved, none of the issues described herein is: (i) dealt with in an earlier return of the taxpayers or a related person, (ii) 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) under objection by the taxpayers 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 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 taxpayers involved, none of the issues contained herein: (i) is in an earlier return of one 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 one of the taxpayers or a related person; (iii) is under objection by one of the taxpayers 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 a ruling previously issued by this Directorate. ... Consequently, the exchanges by DC1 of the Foreignco #1 shares for the Foreignco #3 shares and of the Foreignco #2 shares for the Foreignco #4 shares had no connection with the Proposed Transactions. 7. ... Consequently, the exchange by DC1 of the Foreignco #3 shares for the Opco Preferred Shares was not made in connection with, and was therefore in no way in contemplation of, the Proposed Transactions. 8. ...