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We also acknowledge our telephone conversations in connection herewith. 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 district office or a taxation centre in connection with a tax return already filed, or is under objection or appeal. ...

") would address those leasing arrangements which attempt to establish an artificial connection of the leased employee's employment income to a reserve. ... We reiterate that Guideline 4 was intended to apply in limited circumstances, and that the duties of the employment must be in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserves. ...

They import such meanings as "in relation to", "with reference to" "in connection with". The phrase "in respect of" is probably the widest of any expression intended to convey some connection between two related subject matters. 4 En considérant l'opinion de la Cour Suprême et les articles de la Loi sur les accidents de travail mentionnés ci-avant, nous sommes d'opinion que les sommes que XXXXXXXXXX a reçues en vertu de l'article 178 de la Loi sur les accidents de travail doivent être ajoutées dans le calcul de son revenu en vertu de l'alinéa 56(1)v) de la Loi. ...

We also acknowledge the information provided in subsequent correspondence and during various telephone conversations in connection with your request (XXXXXXXXXX). We understand that to the best of your knowledge and that of the taxpayer involved none of the issues involved in the requested ruling is: (i) in an earlier return of a taxpayer identified in this document or of a related person, (ii) being considered by any Tax Services Office or Taxation Centre of the CCRA in connection with a tax return already filed, (iii) under objection by a taxpayer identified in this document or by a related person; and (iv) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...

They import such meanings as 'in relation to', 'with reference to' or 'in connection with'. The phrase 'in respect of' is probably the widest of any expression intended to convey some connection between two related subject matters. ...

We also acknowledge the information provided in your subsequent correspondence and during our various telephone conversations in connection with your request (XXXXXXXXXX). We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in the ruling request (i) is in an earlier return of the taxpayer or a related person, (ii) is being considered by a tax services office or taxation center 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, (iv) is before the courts or, if a judgment 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. ...

XXXXXXXXXX 2002-017729 XXXXXXXXXX, 2003 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX ("Parentco") (XXXXXXXXXX) XXXXXXXXXX ("Subco") (XXXXXXXXXX) This is in reply to your letters of XXXXXXXXXX in which you request an advance income tax ruling on behalf of Parentco and Subco (collectively the "Companies") and further to our telephone conversations (XXXXXXXXXX) in connection therewith. We understand that, to the best of your knowledge and that of the Companies, none of the issues involved in the ruling request is: (i) in an earlier return of the Companies or a related person, (ii) being considered by a tax services office or tax centre in connection with a previously-filed tax return of the Companies or a related person, (iii) under objection by the Companies 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 not expired, nor (v) the subject of a ruling previously issued by the Directorate to the Companies or a related person other than the ruling and supplemental rulings described in 3 below. ...

We also acknowledge the additional information provided in subsequent correspondence and during our various telephone conversations in connection with your request (XXXXXXXXXX). You advise that to the best of your knowledge and that of the taxpayer referred to above, none of the issues involved in the ruling request is: i) in an earlier return of the taxpayer or a related person; ii) being considered by a tax services office or tax 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) 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 Directorate. ...

Under section 255 of the Income Tax Act (the "Act"), the word "Canada" includes and has always included for the purposes of the Act (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 a province grants a right, licence or privilege to explore for, drill for or take any minerals, petroleum, natural gas or any related hydrocarbons; and (b) the sea and airspace above the submarine areas referred to in (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 (a). Therefore, where the services of a taxpayer are performed in connection with the activities described above in an area described in paragraphs 255(a) and (b) of the Act, the taxpayer is considered to have performed services in Canada for the purposes of the Act. ...

We also acknowledge the information provided in subsequent correspondence and during our various telephone conversations in connection with this matter. ... We understand that, to the best of your knowledge, and that of the taxpayers involved, none of the issues involved in this ruling: (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 one or any of the taxpayers or a related person; (iii) is under objection by one or any of the taxpayers or a related person; (iv) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; or (v) is the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...