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You have advised us that to the best of your knowledge and that of the responsible officers of each of the Applicants, none of the issues involved in this Ruling: (i) is in an earlier tax return of any of the Applicants 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 any of the Applicants or a related person; (ii) is under objection by any of the Applicants or a related person; (iii) is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired; or (iv) is the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

If YCO does not comply with the CRA's request made under subsection 83(3.1) within the ninety-day prescribed period and considering the facts and circumstances surrounding the given situation, the application of subparagraph 152(4)(a)(i) should be considered with respect to Y and the dividend received by him from YCO in 1997. ...

We understand that, to the best of your knowledge and that of the taxpayer, none of the issues contained in the ruling requested herein is: (a) dealt with in an earlier income tax return of A Co or a related person, (b) being considered by a Tax Services Office or a Taxation Centre in connection with a tax return already filed by A Co or a related person, (c) under objection by A Co or a related person, (d) before the Courts, or if a judgement has been issued, the time limit for appeal to a higher court has expired, or (e) the subject of a previous ruling issued by the Income Tax Rulings Directorate of the CRA. ...

We understand that, to the best of your knowledge and that of the taxpayer involved, 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 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; or (v) is the subject of a Ruling previously issued by the Directorate. ...

Other than that ruling, to the best of your knowledge and that of the taxpayer, none of the issues in this ruling request is: (i) involved 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 (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

However, the gift for perpetuity of a conservation easement, that qualifies as an ecological gift, as defined in the Act, by the owner of land is generally considered to be a disposition of part of real property situated in Canada. ...

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 is: (a) dealt with in an earlier return of A Co, B Co, C Co or a related person; (b) being considered by a tax services office or a taxation centre in connection with a tax return already filed by A Co, B Co, C Co or a related person; (c) under objection by A Co, B Co, C Co 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 previous ruling issued by the Income Tax Rulings Directorate of the CRA. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling request are: (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 taxpayer or a related person; (iii) under objection by the taxpayer 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. ...

A determination by Transmission that particular costs are required to be incurred by a Generator in order to permit interconnection with the provincial transmission system is a factor to be considered in determining whether such costs were incurred for the purpose of making a service connection to the project for the transmission of electricity to a purchaser thereof as required by paragraph 1219(1)(a) of the Regulations. ...

We understand that to the best of your knowledge and that of the taxpayer involved, none of the issues contained herein: (i) is in an earlier tax 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 judgement has been issued, the time limit for appeal to a higher court has not expired; or (v) is the subject of an advance income tax ruling previously issued by the Income Tax Rulings Directorate. ...