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Ruling

2004 Ruling 2003-0046771R3 - split-up butterfly

To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in this ruling request is (i) in an earlier return of one 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 one of the taxpayers or a related person; (iii) under objection by one of 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. ...
Ruling

2004 Ruling 2004-0070491R3 - Loss Consolidation

To the best of your knowledge and the knowledge of the taxpayers involved in the Proposed Transactions, none of the issues described in this ruling is: (a) in an earlier tax return of a taxpayer involved or a related person; (b) being considered by a tax services office or taxation centre in connection with any tax return previously filed by a taxpayer involved or a related person; (c) under objection or appeal by a taxpayer involved or a related person; (d) before the courts; or (e) the subject of a ruling previously issued to a taxpayer involved or a related person. ...
Ruling

2004 Ruling 2004-0056921R3 - stock options; conversion of plans

To the best of your and the Corporation's knowledge, none of the issues involved in this ruling are: (i) in an earlier return of the Corporation, a Participant, or any person related to the Corporation or a Participant; (ii) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Corporation, a Participant, or any person related to the Corporation or a Participant; (iii) under objection by the Corporation, a Participant, or any person related to the Corporation or a Participant; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; nor (v) the subject of a ruling previously issued by the Directorate to the Corporation. ...
Ruling

2004 Ruling 2004-0088271R3 - Split-Up Butterfly

You have advised us that to the best of your knowledge and that of the taxpayers involved none of the issues involved in this ruling request are: (i) in an earlier return of the taxpayers or related persons; (ii) being considered by a tax services office ("TSO") or taxation centre ("TC") in connection with a previously filed tax return of the taxpayers or related persons; (iii) under objection by the taxpayers or related persons; (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. ...
Ruling

2004 Ruling 2004-0093101R3 - Butterfly - Family Farm Corporation

You have advised us that to the best of your knowledge and that of the taxpayers involved none of the issues involved in this ruling request are: (i) in an earlier return of the taxpayer or a related person; (ii) being considered by a tax services office ("TSO") or taxation centre ("TC") 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. ...
Ruling

2000 Ruling 2000-0014603 - Internal Reorganization

To the best of your knowledge, and that of the taxpayer involved, none of the issues contained herein is: (i) dealt with 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) subject to a ruling previously issued by the Income Tax Rulings 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. ...
Ruling

2001 Ruling 2000-0053013 - Loss Consolidation

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 not expired; or (v) is the subject of a ruling previously issued by the Directorate. ...
Ruling

2001 Ruling 2000-0046523 - Split-up butterfly

To the best of your knowledge, and that of any of the taxpayers, none of the issues involved in this ruling request is: (i) involved in an earlier return of any 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 any of the taxpayers or a related person; (iii) under objection by any of the taxpayers or a related person; (iv) before the courts; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...
Ruling

2001 Ruling 2000-0044193 - XXXXXXXXXX - Butterfly

You have advised us that to the best of your knowledge and that of the taxpayers involved none of the issues involved in this ruling request: (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; (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 considered by the Directorate. ...
Ruling

2001 Ruling 2000-0042353 - split-up butterfly

You have been advised by your clients that none of the issues contained herein is: (i) in an earlier return of the taxpayer or related persons; (ii) being considered by a Tax Services Office or Taxation Centre in connection with a previously filed return of the taxpayer or related persons; (iii) under objection by the taxpayer or related persons; (iv) before the courts; or (v) the subject of a ruling previously issued by the Directorate. ...

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