Search - connection

To the best of your knowledge and that of the taxpayers involved: a)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 b)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 the taxpayers involved: a)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 b)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 the taxpayers involved, none of the issues contained herein: (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 judgement has been issued, the time limit for appeal to a higher court has not expired; and (v)is the subject of a ruling previously issued by the Directorate. ...

You advise that to the best of your knowledge and that of the taxpayers noted above, none of the issues involved in the ruling request has been considered by a taxation services office or a taxation centre in connection with a tax return already filed, and none of the issues involved in the ruling request is the subject of any notice of objection or is under appeal. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein: (a)is in an earlier return of the taxpayers or a related person; (b)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; (c)is under objection by the taxpayers or a related person; or (d)is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ...

ADDITIONAL INFORMATION 40.To the best of your knowledge, and that of the parties to this ruling, none of the issues involved in the requested rulings is being considered by a tax services office or a taxation centre in connection with an income tax return already filed, or is under objection or appeal. 41.There will not be, as part of the series of transactions or events that includes the proposed transactions described herein, any (a) disposition of property in the circumstances described in subparagraph 55(3.1)(b)(i), (b) acquisition of control in the circumstances described in subparagraph 55(3.1)(b)(ii), (c) acquisition of property in the circumstances described in paragraph 55(3.1)(c), (d) acquisition of property in the circumstances described in paragraph 55(3.1)(d), which has not been described herein. 42.Other than as a result of the proposed amalgamation of the Subject Corporations described in paragraph 28 of Proposed Transactions, no property has or will become property of any of the Subject Corporations or Amalco in contemplation of the proposed transactions. 43.None of the shares referred to in this ruling application is or will be subject to a guarantee agreement, within the meaning of subsection 112(2.2) of the Act, that is given by a person or partnership (other than the issuer of the share or an individual other than a trust), that is a specified financial institution or a specified person in relation to such an institution. 44.None of the shares described herein have been or will be issued or acquired as part of a transaction or event or series of transactions or events of the type described in subsection 112(2.5) of the Act. 45.None of the shares described herein has been or will be the subject of a dividend rental arrangement as that term is defined in subsection 248(1) of the Act. ...

We understand that none of the issues involved in the ruling request, to the best of your knowledge and that of the taxpayers involved: i) is in an earlier return of the taxpayers or a related person, ii) is being considered by an office of Revenue Canada 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 judgement has been issued, the time limit for appeal to a higher court has not expired, and v) is the subject of a ruling previously issued by the Directorate to the taxpayers or a related person. ...

We understand that to the best of your knowledge and that of the taxpayers involved 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, or is under objection or appeal. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained 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) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ...

To the best of your knowledge, and that of the taxpayers, none of the issues involved in the ruling request is: (i) involved 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 tax return previously filed by the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) before the courts and there is no judgment that has been issued in which the time limit for appeal to a higher court has not expired; and (v) the subject of a ruling previously issued by the Income Tax Rulings and Interpretations Directorate. ...