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Please note that we have not considered the impact of the transactions in paragraph 5 since there is no evidence that this is a common situation or one that could have an impact on a number of taxpayers. ...

Principal Issues: 1) Whether amounts received by a taxpayer in a particular situation should be included in its income by virtue of paragraph 12(1)(a) of the Act and whether such taxpayer may claim a reserve for a reasonable amount pursuant to paragraph 20(1)(m) of the Act. 2) Whether such amounts would be considered active business income for purposes of the Act. ...

You have advised us that to the best of your knowledge and that of the taxpayers involved none of the issues involved in this ruling is: (i) in an earlier return of any of the taxpayers or a related person; (ii) being considered by a tax services office ("TSO") or taxation centre ("TC") in connection with a previously filed tax return of any of the taxpayers or a related person; (iii) under objection by any of 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 Income Tax Rulings Directorate. ...

We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved with this Ruling request: (i) is in an earlier return of the taxpayers or a related person; (ii) is being considered by a Tax Services Office or a 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. ...

All of the relevant facts must be considered in concluding whether a specific scenario come within the ambit of subsection 105(1) of the Act. ...

being considered by a tax services office or by a taxation centre in connection with a previously filed tax return of the Corporation or a related person;? ...

To the best of your knowledge and that of the Company, none of the issues contained herein: (i) is in an earlier tax return of the Company 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 Company or a related person; (iii) is under objection by the Company 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 expired; or (v) is the subject of an advance income tax ruling previously issued by the Income Tax Rulings Directorate to the Company or a related person. ...

Reduction under subsection 125(5.1), if applicable While not considered in examples 1 and 2, and subject to the enactment of the proposed amendment to subsection 125(5.1), please note that the business limits as otherwise computed in the examples, may be further reduced pursuant to the formula in subsection 125(5.1) of the Act if tax under Part I.3 was payable by any of the corporations for their last taxation year ending in the preceding calendar year. ...

Based on CCRA's administrative position, subsections 40(3.3) and 40(3.4) would be considered to apply to deem a portion only of the transferor's loss to be nil in the second given fact situation. ...

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 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. ...