Search - connection

You have been advised by your clients that none of the issues involved in this ruling request is, to the best of their knowledge, being considered by a District Taxation Office or Taxation Centre in connection with any tax return already filed and, further, none of the issues involved is the subject of any Notice of Objection or is under appeal. ... In connection with each transfer of shares described above, the transferor and the transferee will jointly elect in prescribed form within the time limit referred to in subsection 85(6), to have the provisions of subsection 85(1) applied to the transfer. ...

We understand that to the best of your knowledge and that of the Taxpayers, none of the proposed transactions and/or issues involved in this ruling are the same as or substantially similar to transactions and/or issues that are: (a) in a previously filed 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 or a related person; (d) the subject of a current or completed court process involving the Taxpayers or a related person; or (e) the subject of a ruling previously considered by the Income Tax Rulings Directorate in relation to the Taxpayers or a related person. ... In connection with the winding-up of DCAmalco, DCAmalco will distribute all of its assets, which will consist only of TC1 Note and TC2 Note and the rights to any tax refunds referred to in Paragraph 33, to TC1 and TC2 in accordance with their shareholdings. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover Yours truly, XXXXXXXXXX For Division Director Reorganizations Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

PRELIMINARY MATTERS We understand that to the best of your knowledge and that of the Taxpayers, none of the proposed transactions and/or issues involved in this ruling are the same as or substantially similar to transactions and/or issues that are: i. in a previously filed return of the Taxpayers or a related person and; A. being considered by the Canada Revenue Agency in connection with such return; B. under objection by the Taxpayers or a related person; or C. the subject of a current or completed court process involving the Taxpayers or a related person; or ii. the subject of a ruling previously considered by the Income Tax Rulings Directorate. ... In connection with the winding-up of TC1 Sub, the TC1 Sub Redemption Note will be assumed by TC1. 37. ... 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 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 tax ruling previously issued by the Income Tax Rulings Directorate. ... The following are some of the relevant facts related to DC’s assets and liabilities: Goodwill There is no goodwill in DC, as there is no value attributable to goodwill in connection with DC’s XXXXXXXXXX. ... For greater certainty, the Agreed Amount in respect of each such Eligible Property will be within the limits prescribed as follows: (a) in the case of Capital Property (other than Depreciable Property of a prescribed class) described in paragraph 85(1)(c.1), 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, an amount equal to the least of the amounts described in subparagraphs 85(1)(e)(i), (ii) and (iii); and (c) in the case of farm inventory owned in connection with the farming business carried on by DC, an amount determined in accordance with the formula set out in paragraph 85(1)(c.2). ...

CONFIRMATION To the best of your knowledge and that of the taxpayers involved, none of the proposed transactions or issues involved in this Ruling request are the same as or substantially similar to transactions or issues that are: i. in a previously filed return of the taxpayers or a related person and: A. being considered by the CRA in connection with such return; B. under objection by the taxpayers or a related person; or C. the subject of a current or completed court process involving the taxpayers or a related person; or ii. the subject of a Ruling request previously considered by the Income Tax Rulings Directorate. ... In connection with the amalgamation, Amalco will designate, in its return of income for its XXXXXXXXXX taxation year, an amount under the provisions of subsection 87(11) and paragraphs 88(1)(c) and (d) and within the limits thereto, to increase the ACB of the capital property, other than ineligible property, previously owned by Aco and Bco. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

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. ... It is contemplated that the Manager may, in connection with the Proposed Transactions or in the near future, assign its rights and obligations under the Management Agreement, the Administration Agreement and the Governance Agreement to a related corporation that meets the conditions described in paragraphs 5 and 6, and that would agree to replace it as manager under those agreements. ... On the day following the day on which the election described in paragraph 20 is made, MFC and Opco (hereinafter referred to as “predecessor corporations”) will undertake a vertical short-form amalgamation under the provisions of the First Act to form Amalco MFC in such a manner that: a) All of the property (except any amounts receivable from any predecessor corporation or shares of the capital stock of any predecessor corporation) of the predecessor corporations held immediately before the amalgamation will become property of Amalco MFC by virtue of the amalgamation; b) All of the liabilities (except any amounts payable to any predecessor corporation) of the predecessor corporations immediately before the amalgamation will become liabilities of Amalco MFC by virtue of the amalgamation; c) All of the Opco Shares and Opco Notes held by MFC immediately prior to the amalgamation will be cancelled by virtue of the amalgamation; d) In accordance with the provisions of the First Act, the articles of amalgamation of Amalco MFC will be the same as the articles of MFC, and Amalco MFC will not issue any securities in connection with the amalgamation; and e) From the time of amalgamation, Amalco MFC will not have any activity or undertaking other than the ownership of the LP Units formerly owned by Opco and the cash formerly owned by MFC, and the completion of the ensuing Proposed Transactions. 23. ...

You have asked us to comment on the taxation treatment of the following: a) the discounts; b) the related financing costs incurred in connection with the commercial paper zero coupon bonds; c) the related selling concessions incurred in connection with the Eurodollar Bonds; and, d) the responsibility for withholding and remitting Part XIII taxes. ... The taxpayer issued debentures to raise money for use in making loans and paid finder's fees in connection with the issuance of the debentures. ...

We also acknowledge the additional information provided to us in your emails in connection with your request. We understand that, to the best of your knowledge and that of the taxpayer, except to the extent described herein, none of the Transactions and/or issues in this letter are the same as or substantially similar to transactions and/or issues that are: i. in a previously filed tax return of the taxpayer or a related person and: a. being considered by the CRA in connection with such return; b. under objection by the taxpayer or a related person; or c. the subject of a current or completed court process involving the taxpayer or a related person; or ii. the subject of a Ruling request previously considered by the Directorate. ... An invoice for our fees in connection with this Ruling will be forwarded to you under separate cover. ...

We understand that to the best of your knowledge and that of the Taxpayers, none of the proposed transactions and/or issues involved in this ruling are the same as, or substantially similar to, transactions and/or issues that are: (a) in a previously filed tax return of the Taxpayers or a related person; (b) being considered by the CRA in connection with a previously filed tax return of the Taxpayers or a person related to the Taxpayers; (c) under objection by the Taxpayers or a person related to the Taxpayers; (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; and (e) the subject of an advance income tax ruling previously issued by the Income Tax Rulings Directorate of the CRA in connection with the Taxpayers or a person related to the Taxpayers. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

We understand that to the best of your knowledge and that of the Taxpayers, none of the proposed transactions and/or issues involved in this Ruling request are the same as or substantially similar to transactions or issues that are: (a) in a previously filed tax return of the Taxpayers or a related person and; (i) being considered by the CRA in connection with any such tax return; (ii) under objection by the Taxpayers or a related person; (iii) the subject of a current or completed court process involving the Taxpayers or a related person; or (b) the subject of a ruling request previously considered by the Income Tax Ruling Directorate in relation to the Taxpayers or a related person. ... Where the amount determined under subparagraph 98(5)(a)(i) exceeds the amount determined under paragraph 98(5)(a)(ii), ParentCo will make designations under paragraph 98(5)(c) in respect of the common shares of Pubco and/or the Land that is transferred to it in connection with the cessation of Partnership C by filing a statement that contains all relevant information with ParentCo’s income tax return for the taxation year in which it received the partnership property. ... Where the amount determined under subparagraph 98(5)(a)(i) exceeds the amount determined under paragraph 98(5)(a)(ii), ParentCo will make designations under paragraph 98(5)(c) in respect of the common shares of Pubco and/or the Land that is transferred to it in connection with the cessation of Partnership D by filing a statement that contains all relevant information with ParentCo’s income tax return for the taxation year in which it received the partnership property. ...