Search - considered

XXXXXXXXXX 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 taxpayer(s) 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(s) or a related person; iii) is under objection by the taxpayer(s) 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 Revenue Canada or the Canada Customs and Revenue Agency. ... Any amount of unpaid principal which the PLP owes on account of the Production Loans (the "Unpaid Loans") will be a limited-recourse amount of the PLP, with the result that: (i) the provisions of subsection 143.2(6) of the Act will apply to reduce the PLP's expenditures (including the amount of the NCLE) to the extent that the amount of the Unpaid Loans can reasonably be considered to relate to such expenditures incurred by the PLP; (ii) at the time that all or a portion of the Unpaid Loans are repaid by the PLP, the provisions of subsection 143.2(10) of the Act will apply to deem such expenditures to have been made or incurred at the time of, and to the extent of, the repayment; and (iii) the Unpaid Loans will not, in and of themselves, result in the application of subsection 143.2(6) of the Act to reduce the cost of the Class A Units acquired by the MLP or the cost of the MLP Units acquired by the Investors. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (i) dealt with 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 tax return previously filed by the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) before the courts, and there is no judgement that has been issued in which the time limit for appeal to a higher court has not expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings and Interpretations Directorate. ... For greater certainty, any tax accounts, such as the balance of any non-capital losses, RDTOH or CDA of Opco, will not be considered property for purposes of the proposed transactions described herein. 14. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues involved in this request: (a) is involved 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 tax return already filed by the taxpayer or a related person, (c) is under objection, and (d) is before the courts or, if a judgement has been issued, the time limit for appeal has not expired. ... For greater certainty, the proposed transactions described herein, in and by themselves, will not be considered to result in any disposition or increase in interest described in any of subparagraphs 55(3)(a)(i) to (v). ...

Provided the XXXXXXXXXX Loans arose from one or more loans or "lending assets" within the meaning of subsection 248(1), made or acquired by XXXXXXXXXX in the course of its money-lending business, the XXXXXXXXXX Loans reacquired by XXXXXXXXXX or the Inter-Company Loan acquired by XXXXXXXXXX as described in paragraph 30 above, will be considered to have been acquired by XXXXXXXXXX in the ordinary course of its money lending business for purposes of paragraphs 20(1)(l) and 20(1)(p). ... To the extent that XXXXXXXXXX assumes the liabilities of the Partnership immediately before the acquisition of XXXXXXXXXX interest in the Partnership (as described in paragraph 19 above) XXXXXXXXXX will be considered to have made a contribution of capital to the Partnership immediately before the Partnership ceases to exist. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (i) dealt with 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) subject to a ruling previously issued by the Income Tax Rulings Directorate; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ... For greater certainty, any tax accounts of Opco, such as the balance of any losses available for carryforward, if any, will not be considered property of Opco for purposes of the proposed transactions described herein. 58. ...

We understand that, to the best of your knowledge, none of the issues raised in this ruling is being considered by a Taxation Services Office or Taxation Centre in connection with an income tax return already filed, is the subject of any notice of objection or is under appeal. ... In our view, in any period during which the First Nation has the authority respecting the geographic area of the Reserve, has acted or previously acted on, the authority to regulate in the areas typical of a municipality and continues to provide community services of the type in paragraphs 17 to 37 above, the First Nation will be considered to be a municipality in Canada within the meaning of paragraph 149(1)(c) of the Act and, accordingly, no tax will be payable under Part I by the First Nation on any dividends paid by the Company to which subsection 56(4) of the Act applies. ...

We also acknowledge the additional information in your letters of XXXXXXXXXX as well as your earlier correspondence dated XXXXXXXXXX We understand that, to the best of your knowledge and that of the directors and officers of XXXXXXXXXX/A, none of the issues raised in this ruling request is (i) in an earlier return of the taxpayer 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 taxpayer or a related person, (iii) under objection by the taxpayer or a related person, (iv) before the courts or, if a judgement 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 us. ... Provided that the shares of the subsidiaries of XXXXXXXXXX K and the shares of XXXXXXXXXX/H are capital property to XXXXXXXXXX/K and XXXXXXXXXX/B, respectively, prior to the Proposed Transactions, (i) none of the Proposed Transactions described herein will cause such shares to cease to be capital property to XXXXXXXXXX/K or XXXXXXXXXX/B, respectively, and (ii) the common shares of New XXXXXXXXXX/K issued to XXXXXXXXXX/K as consideration for the transfer of the shares of such subsidiaries and of XXXXXXXXXX/H, as described in paragraph 35(b) hereof, will be considered to be capital property to XXXXXXXXXX/K and Amalco 1. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (i) dealt with 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; or (iv) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ... For greater certainty, any tax accounts of Opco, such as the balance of any losses available for carryforward, will not be considered property of Opco for purposes of the proposed transactions set out herein. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues involved in this request: (a) is involved 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 tax return already filed by the taxpayer 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. ... For greater certainty, the proposed transactions described herein, in and by themselves, will not be considered to result in any disposition or increase in interest described in any of subparagraphs 55(3)(a)(i) to (v). ...

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 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 the taxpayers or a related person; (iii) is under objection by the taxpayers or a related person; (iv) is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired; or (v) is the subject of a ruling previously issued by the Directorate. ... For greater certainty, the proposed transactions described in paragraphs 5 to 12 herein, in and by themselves, will not be considered to result in any disposition or increase in interest described in any of subparagraphs 55(3)(a)(i) to (v) of the Act. ...