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In this regard, it is to be noted that even if the Commissions could be considered as being subject to subparagraph 212(1)(d)(iii) of the Act as you suggested in your request, they would still not qualify as "royalties" for the purposes of the Convention since payments for services do not come within the definition of that term as contained in Article XII(4) of the Convention (see documents # E 50278, E 9306027 and E 2000-0048107). ...

We understand that, to the best of your knowledge and that of the Employer, none of the issues involved in the ruling request is: (i) in an earlier return of the Employer 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 Employer or a related person, (iii) under objection by the Employer 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; nor (v) the subject of a ruling previously issued by the Directorate. ...

For this purpose, the settlor of a trust who also has an interest in that trust is not considered to have acquired an interest in the trust for consideration solely because of his or her transfer of property to the trust. ...

We acknowledge receipt of the additional information provided on XXXXXXXXXX XXXXXXXXXX We understand that, to the best of your knowledge, 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 Directorate. ...

To the best of your knowledge, and that of the taxpayers named herein, none of the issues involved in this advance income tax ruling request is under objection or appeal or is being considered by any tax services office or taxation centre of the Canada Customs and Revenue Agency in connection with any income tax return already filed. ...

To the best of your knowledge and the knowledge of the Employer and the Purchaser, none of the issues involved in this ruling are: (a) in an earlier return of the Employer, the Purchaser, or the Employees, or any person related to the Employer, the Purchaser or the Employees; (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Employer, the Purchaser, the Employees, or any person related to the Employer, the Purchaser or the Employees; (c) under objection by the Employer, the Purchaser, the Employees, or any person related to the Employer, the Purchaser or the Employees; (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; nor (e) the subject of a ruling previously issued by the Directorate to the Employer, the Purchaser, the Employees, or any person related to the Employer, the Purchaser or the Employees. ...

You advise that to the best of your knowledge and that of the taxpayers referred to above, none of the issues involved in the ruling request is: i. in an earlier return of the taxpayers 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 taxpayers or a related person; iii. under objection by 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 Directorate. ...

We understand that to the best of your knowledge and that of the taxpayers 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 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 and no judgment has been previously issued; or (v) is the subject of a ruling previously issued by the Income Tax Rulings Directorate to the taxpayer or a related person. ...

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 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, and (v) is the subject of a ruling previously issued by the Directorate Unless otherwise stated, all references to statute are to the Income Tax Act R.S.C. 1985 (5th Supp.), c.1, as amended (the "Act") and all terms and conditions used herein that are defined in the Act have the meaning given in such definition unless otherwise indicated. ...

To the best of your knowledge and the knowledge of the Employer, none of the issues involved in this request for advance income tax rulings are: (a) in an earlier return of the Employer or a person related to the Employer; (b) being considered by a tax services office or taxation centre in connection with a previously filed return of the Employer or of a person related to the Employer; (c) under objection by the Employer or by a person related to the Employer; (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; nor (e) subject to a ruling previously issued by the Income Tax Rulings Directorate to the Employer. ...