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Ruling

2002 Ruling 2001-0114863 - PARTNERSHIP LIFE INSURANCE

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 referred to above, none of the issues involved in the 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 not expired; or (v) the subject of a ruling previously issued by the Directorate. ...
Technical Interpretation - Internal

24 June 2002 Internal T.I. 2002-0140707 - RPP FUNDING

Nevertheless, the technical notes to paragraph 8502(d) provides that in addition to the distributions that are listed, a plan may provide for the payment of all reasonable administrative, investment and similar expenses incurred in connection with the plan. ... Nevertheless, the July 31, 1991 Technical Notes to paragraph 8502(d) of the Regulations provides that in addition to the distributions that are listed, "a plan may provide for the payment of all reasonable administrative, investment and similar expenses incurred in connection with the plan". ...
Ruling

2002 Ruling 2002-0149133 - XXXXXXXXXX

We also acknowledge the information provided in subsequent correspondence and during our various telephone conversations in connection with your request (XXXXXXXXXX). We understand that, to the best of your knowledge and the Organization's knowledge, none of the issues involved in the ruling request (i) is in an earlier return of the Organization 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 Organization or a related person, (iii) is under objection by the Organization 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. ...
Ruling

2002 Ruling 2001-0112373 - TAX TREATMENT OF XXXXXXXXXX

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. ...
Ruling

2002 Ruling 2002-0174333 - GIFTS BY WILL

We also acknowledge the information provided in subsequent correspondence and during our 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. ...
Ruling

1999 Ruling 9915993 - BUMP ON A VERTICAL AMALGAMATION

Furthermore, these issues are not under objection or appeal and are not being considered by any of the tax services office or taxation centres in connection with any tax return already filed and they are not the subject of a ruling previously issued by the Directorate. ... In connection with the amalgamation of XXXXXXXXXX to form MergeCo, a designation will be made under the provisions of subsection 87(11), and paragraph 88(1)(d) to increase, within the limits described in paragraphs 88(1)(d), the ACB of certain capital property (other than ineligible property as defined in paragraph 88(1)(c)) owned by XXXXXXXXXX immediately before the amalgamation. ...
Ruling

1999 Ruling 9917313 - XXXXXXXXXX

We understand that to the best of your knowledge, and that of the taxpayers involved, none of the matters considered in this ruling request are: (a) in an earlier return of the taxpayers or related persons; (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the taxpayers or related persons; (c) under objection by the taxpayers or related persons; (d) before the courts; or (e) the subject of a ruling previously issued by this Directorate to the taxpayers or related persons. ... The Fund will incur a variety of costs and expenses in connection with its investment undertaking. ...
Ruling

2000 Ruling 1999-0014853 - MUTUAL FUND CORPORATION WINDING-UP

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 related persons; II. being considered by a taxation services office or a taxation centre in connection with a previously filed tax return of the taxpayer or related persons; III. under objection by the taxpayer 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 Directorate. ... In computing the amount of its accrued liabilities, a reasonable provision will be established for the costs anticipated to be incurred in connection with the winding-up. ...
Ruling

2000 Ruling 1999-0014333 - Wind Up of Partnership

XXXXXXXXXX XXXXXXXXXX 1999-001433 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 2000 Dear Sirs: Re: Advance Income Tax Ruling XXXXXXXXXX We are writing in connection with your letter dated XXXXXXXXXX requesting an advance income tax ruling on behalf of XXXXXXXXXX ("H") and XXXXXXXXXX ("W"). ... You advise that to the best of your knowledge, none of the issues contained herein: (a) is in an earlier return of H or W 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 H or W or a related person; (c) is under objection by the H or W 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; or (e) is the subject of a ruling previously issued by the Income Tax Rulings Directorate of the Canada Customs and Revenue Agency. ...
Miscellaneous severed letter

5 June 2000 Income Tax Severed Letter 2000-0008206 - Investor Rules; Film Tax Credits

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. ...

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