Search - considered

To the best of your knowledge and that of the taxpayers, none of the issues in this ruling request is: (i) being considered by a tax services office or taxation centre in connection with a previously filed tax return of any of the taxpayers or a related person; (ii) under objection by any of the taxpayers or a related person; or (iii) before the courts. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in this ruling request is (i) in an earlier return of one 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 one of the taxpayers or a related person; (iii) under objection by one 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 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 taxpayer, 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 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 Directorate to the taxpayer or a related person. ...

We understand that to the best of your knowledge, and that of the taxpayer involved, none of the issues involved in the Ruling request: (a) is in an earlier return of A Co. or a related person; (b) is being considered by a tax services office or taxation centre in connection with a previously filed return of A Co., or a related person; (c) is under objection by A Co., or a related person; (d) is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired; or (e) is the subject of a ruling previously issued by the Income Tax Rulings Directorate of the Canada Revenue Agency. ...

To the best of your knowledge and that of the taxpayers, none of the issues in this ruling request is: (i) an issue in an earlier return of any 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 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 (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 above taxpayers, none of the issues involved in the 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, and (v) is the subject of a ruling previously issued by the Canada Revenue Agency ("CRA"). ...

Reasons: The shareholder discharges its debt by a payment in kind (the QBIC shares) the value of which is the value of the debt considered paid in full. ...

We understand that to the best of your knowledge and that of the taxpayer involved, none of the issues involved in this ruling 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, (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 taxpayer, 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 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 if a judgment has been issued, the time limit for appeal to a higher court has expired, and (v) the subject of a ruling previously issued to the taxpayer or a related person by this Directorate. ...

To the best of your knowledge and the knowledge of the Company, none of the issues involved in this request for an advance income tax ruling: (a) is in an earlier return of the Company or of a person related to the Company; (b) is being considered by a tax services office or tax centre in connection with a previously-filed return of the Company or of a person related to the Company; (c) is under objection by the Company or by a person related to the Company; (d) is before the courts; or (e) is the subject of a ruling previously issued by the Income Tax Rulings Directorate to the Company. ...