Search - considered

You have advised that to the best of your knowledge and that of all the taxpayers involved, none of the issues raised in this letter are being considered by any Tax Services Office and/or Taxation Centre in connection with any tax return already filed, nor are any of these issues under objection or appeal. ... Provided the Total XXXXXXXXXX Debt arose from one or more loans made by XXXXXXXXXX in the course of its money lending business, all or any portion of the Total XXXXXXXXXX Debt reacquired by XXXXXXXXXX will be considered to have been acquired by XXXXXXXXXX in the ordinary course of its business of lending money for the purposes of paragraphs 20(1)(1) and 20(1)(p) of the Act. ...

You have advised that, to the best of your knowledge and that of the taxpayers, none of the issues involved in the ruling request is: (i) in previously filed tax returns of the taxpayers or a related person; (ii) being considered by a tax services office or a tax centre in connection with previously filed tax returns of the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) the subject of a current or completed court process involving any of the taxpayers or a related person; or (v) the subject of a ruling previously considered by the Directorate, other than Ruling XXXXXXXXXX issued to you on XXXXXXXXXX in respect of the same taxpayers. ...

We understand that, to the best of your knowledge and that of the XXXXXXXXXX (collectively the "Subsidiaries"), none of the issues in the ruling request is: (a) in an earlier return of the Company, any of the Subsidiaries or a person related to the Company or any of the Subsidiaries, (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Company, any of the Subsidiaries, or a person related to the Company or any of the Subsidiaries, (c) under objection by the Company, any of the Subsidiaries, or a person related to the Company or any of the Subsidiaries, (d) before the courts, or (e) the subject of a ruling previously issued by the Directorate to the Company, any of the Subsidiaries or a person related to the Company or any of the Subsidiaries. ... No benefit will be considered to have been conferred by an Employer on a Final Employer under subsection 15(1) of the Act or under any other provision of the Act by reason only of the Employer making the payment of the reimbursement to the Final Employer described in 13(k) above. ...

You are advised that, to the best of the knowledge of your clients, none of the issues described herein, as they apply specifically to such respective parties, is: (a) in an earlier return; (b) being considered by a tax services office or taxation centre in connection with any tax return previously filed; (c) the subject of any notice of objection or is under appeal; or (d) the subject of a previously issued ruling. ... Any tax accounts such as any non-capital loss, net capital loss, the balance of any RDTOH or capital dividend account will not be considered property for this purpose. 32. ...

To the best of the knowledge of the responsible officers of the existing taxpayer and yourselves, none of the issues involved in this Ruling: (a) is in an earlier tax return of the existing taxpayer or a related person; (b) is being considered by a tax services office or taxation centre in connection with a previously filed tax return of the existing taxpayer or a related person; (c) is under objection by the existing taxpayer or a related person; (d) is before the courts; or (e) is the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... Control, for purposes of the Act, of C will not be considered to be have been acquired by a person or group of persons by reason only of the Proposed Transactions. ...

[Plan section XXXXXXXXXX] (f) In making a determination of an Incentive Amount, the Board shall consider the timing of crediting RUs to the Participant's Account and the vesting requirements applicable to such RUs to ensure that the crediting of the RUs to the Participant's Account and their vesting requirements are not considered a salary deferral arrangement for purposes of the Act and the XXXXXXXXXX [Plan section XXXXXXXXXX] For greater certainty, an Eligible Employee will not be credited with any RUs at the time the Incentive Amount is established but only when the Trustee credits RUs to the Participant's Account. ... To the best of your, the Group's and any Participants' knowledge, none of the issues involved in this ruling are: (i) in an earlier return of any member of the Group or a Participant, or any person related to any member of the Group or a Participant; (ii) being considered by a tax services office or tax centre in connection with a previously filed tax return of any member of the Group or a Participant, or any person related to any member of the Group or a Participant; (iii) under objection by any member of the Group or a Participant, or any person related to any member of the Group or a Participant; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; nor (v) the subject of a ruling previously issued by the Directorate to any member of the Group or a Participant. ...

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 request are: (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 expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... For greater certainty, the Proposed Transactions described herein, in and by themselves, will not be considered to result in a disposition or increase in interest described in subparagraphs 55(3)(a)(i) to (v) with respect to the dividends deemed to be received by Holdings or any of the Newcos. ...

To the best of your knowledge, and that of the parties to this ruling, none of the issues contained in this advance income tax ruling: 1. is in an earlier return of the taxpayer or a related person; 2. is being considered by a tax services office or a taxation centre in connection with a previously filed tax return of the taxpayer or a related person; 3. is under objection by the taxpayer or a related person; 4. is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or 5. is the subject of a ruling previously issued by this Directorate. ... For greater certainty, the amount of any deferred income taxes will not be considered a liability for the purposes of the proposed transactions described herein because such amount does not represent a legal obligation of the particular corporation. 21. ...

To the best of your knowledge, and that of the parties to this ruling, none of the issues contained in this advance income tax ruling: 1. is in an earlier return of the taxpayer or a related person; 2. is being considered by a tax services office or a taxation centre in connection with a previously filed tax return of the taxpayer or a related person; 3. is under objection by the taxpayer or a related person; 4. is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or 5. is the subject of a ruling previously issued by this Directorate. ... In the event of a subsequent disposition of any shares of any of the companies referred to herein, nothing in this ruling should be construed as implying that the transactions described herein will not, for the purposes of subsection 55(3.1), be considered to be part of a series of transactions or events which includes such subsequent disposition of shares. 4. ...

You have been advised by your clients that to the best of their knowledge, none of the issues involved in this ruling request, as they apply specifically to such respective parties: (i) is in an earlier return; (ii) is being considered by a tax services office or taxation centre in connection with a previously filed tax return; (iii) is under objection; (iv) is before the courts; or (v) is the subject of a previously issued ruling. ... For greater certainty, the proposed transactions described herein, in and by themselves, will not be considered to result in any disposition or increase in interest to an unrelated person as described in subparagraphs 55(3)(a)(i) to (v). ...