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We understand that to the best of your knowledge and that of the taxpayers involved: (i)none of the issues involved in the requested rulings are being considered by a district taxation office or a taxation centre in connection with a tax return already filed, and (ii)none of the issues involved in the requested rulings are the subject of any notice of objection or is under appeal. ...

To the best of your knowledge and that of your clients, none of the issues involved in this ruling is being considered by a District Office or a Taxation Centre in connection with any tax return already filed and none of such issues is under objection. ...

You advised that to the best of your knowledge, none of the issues involved in the ruling request is being considered by a Tax Services Office and a Taxation Centre of Revenue Canada in connection with a tax return already filed and none of the issues is under objection or appeal. ...

However, and assuming there are no material alterations to the plan after October 8, 1986, a "statutory arrangement" is deemed to be established on January 1, 1988, and all contributions made under the existing arrangement after January 1, 1988, and property derived therefrom are deemed to be property held in connection with the statutory arrangement. ...

Additional Information To the best of your knowledge, none of the issues involved in this ruling are being considered by a District Office or Taxation Centre in connection with a tax return already filed, and none of the issues are under objection. ...

Physical address for notice or service constitutes the necessary Canadian connection in context of paragraph (d) tests. ...

At the 1982 Conference, the Department stated that it will generally give recognition to a corporation's practice of distributing its profits to shareholder- employees or employees in the form of bonuses, or to a corporation's policy of recompensing its shareholder-managers for profits that are attributable to their special knowledge, skills, connections or other contributions. ...

In connection with an arrangement to sell shares payable on an instalment basis, the shares are sold at a predetermined price with a portion of the sale price payable at the time of the sale and the balance to be paid at some future date in two instalments. ...

In order to qualify to claim the OETC an individual must be a resident in Canada in a taxation year and, throughout any period of more than 6 consecutive months was employed by a person who was a specified employer and performed all or substantially all the duties of employment outside Canada: (a)     in connection with a contract under which the specified employer carried on business outside Canada with respect to a qualified activity, or (b)     for the purpose of obtaining, on behalf of the specified employer a contract to undertake a qualified activity. ...

Section 255 of the Canadian Income Tax Act (the "Act") provides that "Canada" is hereby declared to include and to have always included (a)     the sea bed and subsoil of the submarine areas adjacent to the coasts of Canada in respect of which the Government of Canada or of a province grants a right, license or privilege to explore for, drill for or take any minerals petroleum, natural gas or any related hydocarbons: and (b)     the seas and airspace above the submarine areas referred to in paragraph (a) in respect of any activities carried on in connection with the exploration for or exploitation of the minerals, petroleum, natural gas or hydrocarbons referred to in that paragraph. ...