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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 OPCO, Newco, New 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 OPCO, Newco, New Canco or a related person; (iii) under objection by OPCO, Newco, New 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. ...

In this respect, a debenture issued prior to January 1, 2010, but modified on or after that date will be considered issued on or after January 1, 2010. ...

Such an amount will not be considered as having been paid or as being payable in the year. ...

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 Parent, Subsidiary 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 Parent, Subsidiary or a related person; (iii) under objection by Parent, Subsidiary 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; or (v) before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

On the other hand, unused tax credits can be transferred from one spouse to the other and the pension income splitting could also be considered for one or the other of the tax spouses. ...

Moreover, we are of the opinion that there is a link between all of the elements considered for computing the Québec tax credit for on-the-job training period, including the portion which refers to the salary or wages payable to the eligible supervisor pursuant to the Québec tax legislation, and the eligible salary or wages payable to an eligible trainee. ...

However, if the taxpayer owns two or more units or lots in the same building with an aggregate capital cost of at least $50,000, all such units or lots in the same building are considered to be a single rental property in a separate prescribed class. ...

The Queen 7, the Supreme Court of Canada has clearly indicated that the GAAR should be analyzed in three steps: (1) determine whether a tax benefit exist, (2) determine whether the transaction can be considered as an avoidance transaction, (3) determine whether there is abusive tax avoidance. ...

Thus, a loss carry-back is not considered in element A of the definition of the GRIP in subsection 89(1) of the ITA. ...

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 Lossco, Profitco, Xco 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 Lossco, Profitco, Xco or a related person; (iii) under objection by Lossco, Profitco, Xco 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. ...