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You have advised us that, to the best of your knowledge and that of the taxpayer involved, none of the issues involved in this ruling request are: (i) in an earlier return of the taxpayer or persons related to the taxpayer; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or persons related to the taxpayer; (iii) under objection by the taxpayer or persons related to the taxpayer; (iv) before the courts; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

If, in fact, that cargo handling operation had developed to a stage where it was beyond any reasonable requirements of the company's own ships, it would seem appropriate to treat it as a separate business and, in the context of the question at hand, to exclude those revenues arising in connection with cargo services provided to the other ship owners. ...

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 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) before the courts; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

We understand that to the best of your knowledge and that of the taxpayers on whose behalf this ruling is being requested, none of the issues involved in this ruling request: (a) is in an earlier return of the taxpayers or related persons; (b) is being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or related persons; (c) is under objection by the taxpayers or related persons; (d) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; and (e) is the subject of a ruling previously considered by the Income Tax Rulings Directorate. ...

We understand that to the best of your knowledge and that of the taxpayers on whose behalf this ruling is being requested, none of the issues involved in this ruling request: (a) is in an earlier return of the taxpayers or related persons; (b) is being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or related persons; (c) is under objection by the taxpayers or related persons; (d) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; or (e) is the subject of a ruling previously considered by the Income Tax Rulings Directorate. ...

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 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 the taxpayers; (iii) under objection by the taxpayers or a person related to 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. ...

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 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. ...

To the best of your knowledge and that of the above-referenced taxpayer, none of the issues involved in this ruling is: (a) in an earlier return of the above-referenced taxpayer 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 above-referenced taxpayer or a related person; (c) under objection by the above-referenced taxpayer or a related person; (d) before the courts; or (e) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

R. 2004 DTC 6636 (FCA), the Court upheld the trial judge's reliance on factors such as operational control, economic dependence and family connections to conclude the same person had de facto control over two (2) corporations, which were deemed to be associated pursuant to subsection 256(1) of the ITA. ...

To the best of your knowledge and that of your client, none of the issues involved in the ruling request is: in an earlier return of your client or a related person, being considered by a tax services office or taxation center in connection with a previously filed tax return of your client or a related person, under objection by your client or a related person, before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired, or the subject of a ruling previously considered by the Directorate in respect of your client or a related person. ...