Search - considered

To the best of your knowledge and that of the taxpayers, none of the issues involved in the requested rulings:- is in an earlier return filed by the taxpayer, or a related person;- is being considered by a Tax Services Office or taxation centre in connection with an income tax return previously filed by the taxpayer or a related person;- is subject to a notice of objection under section 165 of the Act or is otherwise under appeal or,- except as disclosed herein, is the subject of a previous ruling. ...

We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in the ruling request: (i) is in an earlier return of any of the taxpayers 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 any of the taxpayers or a related person; (iii) is under objection by any of the taxpayers or a related person; or (iv) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...

We understand that, to the best of your knowledge and that of the Corporation, none of the issues involved in this ruling request is: (a) in an earlier return of the Corporation or a related person; (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Corporation or a related person; (c) under objection by the Corporation or a related person; (d) before the courts; nor (e) the subject of a ruling previously issued to the Corporation or a related person by the Income Tax Rulings Directorate. ...

You advise that to the best of your knowledge and that of the taxpayer referred to above, none of the issues involved in the ruling request is: (i) in an earlier return of the taxpayer or a related person; (ii) being considered by a tax services office or tax 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 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 Directorate. ...

In such a case, the impact of subsection 248(3) should be considered. ...

To the best of your knowledge, and that of the Company, none of the issues involved in the ruling request is: i. in an earlier return of the Company 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 the Company or a related person; iii. under objection by the Company 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; and v. the subject of a ruling previously issued by the Directorate to the Company or a related person. ...

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

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. ...

We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in the ruling request: (i) is in an earlier return of a 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 a taxpayer or a related person; (iii) is under objection by a 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; and (v) is the subject of a ruling previously issued by the Directorate. ...

To the best of your knowledge and that of X Co, none of the issues involved in this ruling contained herein is: (i) in a return of X Co or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of X Co or a related person; (iii) under objection by X Co 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 of the CRA. ...