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To the best of your knowledge, and that of the parties to this ruling, none of the issues contained in this advance income tax ruling: 1. is in an earlier return of the taxpayer or a related person; 2. is being considered by a tax services office or a taxation centre in connection with a previously filed tax return of the taxpayer or a related person; 3. is under objection by the taxpayer or a related person; 4. is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or 5. is the subject of a ruling previously issued by this Directorate. ...

You have advised that to the best of your knowledge and that of the taxpayers involved none of the issues involved in this ruling request: (a) is involved 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 tax return already filed by the taxpayers or a related person, (c) is under objection, (d) is before the courts or, if a judgement has been issued, the time limit for appeal has not expired, and (e) is the subject of a ruling previously issued by the Income Tax Rulings and Interpretations Directorate. ...

We understand that to the best of your knowledge and that of the taxpayer involved, none of the issues involved in this ruling request: a) is in an earlier return of the taxpayer 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 taxpayer or a related person; c) is under objection by the taxpayer or a related person; d) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; e) is the subject of a ruling previously issued by the Rulings and Interpretations Directorate of Revenue Canada. ...

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 taxpayer 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 taxpayer or a related person; (iii) is under objection by the taxpayer or a related person; or (iv) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...

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, none of the issues involved in the ruling request is: i. in a previously filed tax return of any of the Taxpayers or a related person; ii. being considered by a tax services office or a tax 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. the subject of a current or completed court process involving the Taxpayers or a related person; or v. the subject of a ruling request previously considered by the Directorate. ...

We understand that to the best of your knowledge and that of the Taxpayers, none of the proposed transactions or issues involved in this Ruling are the same as or substantially similar to transactions 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. ...

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 tax 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 taxpayer issued debentures to raise money for use in making loans and paid finder's, fees in connection with the issuance of the debentures. ...

The trust will use the proceeds of partial notes receivable repayments to pay its income taxes arising from taxable dividends and taxable capital gains realized in connection with the disclosed transactions. 1) Does section 84.1 apply to the Proposed Transactions? ...