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We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling request herein are: (i) dealt with in an earlier return of Parentco, #Co, Aco, Bco, Cco, Canco or a related person; (ii) being considered by a tax services office or a taxation centre in connection with a tax return already filed by Parentco, #Co, Aco, Bco, Cco, Canco or a related person; (iii) under objection by Parentco, #Co, Aco, Bco, Cco, Canco or a related person; (iv) the subject of a previous ruling issued by the Income Tax Rulings Directorate to the taxpayers or a related person; nor, (v) before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

Raisons: (1) Wording of the provision. (2) Given the fact that the transitional reserve is temporary and that it may reasonably be considered that the qualifying transitional income on which the reserve is based results in an increase in value of the shares. ...

We understand that, to the best of your knowledge and that of the taxpayer, none of the issues involved in the ruling request is: (i) in an earlier tax return of the taxpayer or a related person; (ii) being considered by a tax services office or a tax centre in connection with a tax return already filed by the taxpayer or a related person; (iii) under objection by the taxpayer or a related person; (iv) before the courts; or (v) the subject of a ruling previously issued by the Directorate to the taxpayer or a related person. ...

To the best of your knowledge and that of the above-referenced taxpayers, none of the issues involved in this ruling is: a) dealt with in an earlier tax return of the above-referenced 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 above-referenced taxpayers or a related person, c) under objection or appeal by the above-referenced taxpayers, or a related person, d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired, or e) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

If the paying affiliate (CCo in this case) does not have sufficient exempt surplus or taxable surplus, the dividend will be considered to be paid from CCo's pre-acquisition surplus. ...

We understand that, to the best of your knowledge and that of the taxpayer, none of the issues involved in this 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 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; (iv) is before the courts or, if a judgment 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 Income Tax Rulings Directorate. ...

In arriving at this conclusion in the context of the facts submitted, we considered the application of paragraph 5901(2)(b) and subsections 5901(2.1) and (2.2) of the Regulations, taking into account the coming-into-force and transitional rules set out in subsection 79(2) of Bill C-48. ...

You have advised that to the best of your knowledge, and that of the above-referenced taxpayers involved, none of the issues contained herein is: (i) dealt with in an earlier tax return of the taxpayers or a related person; (ii) being considered by a tax services office or taxation centre in connection with any 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 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. ...

For the purpose of paragraph 94(3)(g), we are on the opinion that the amount of deemed dividend is considered to be included in the total income of the Estate pursuant to paragraph 12(1)(j) and 82(1)(e). ...

b) If the attributed income retains its nature, how the CRA expects the tax practitioners to prepare and file the T3 Trust Income Tax and Information Return and the T3 Statement of Trust Income Allocations and Designations ("T3 Statement") in order to ensure that the rental income is considered in calculating the taxpayer's "RRSP deduction limit" under subsection 146(1)? ...