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Results 19021 - 19030 of 19053 for considered
Ruling

2017 Ruling 2016-0629511R3 - Post-Mortem Planning and Extraction of "Hard ACB"

We understand that to the best of your knowledge and that of the taxpayers involved, none of the issues described herein is: (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) 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. ...
Ruling

2017 Ruling 2016-0679281R3 - subsections 84(4.1) and 86(1)

To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in this ruling request is (i) in a previously filed tax return of the taxpayers or persons related to the taxpayers; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or persons related to the taxpayers; (iii) under objection by the taxpayers or persons related to the taxpayers; (iv) the subject of a current or completed court process involving the taxpayers or persons related to the taxpayers; or (v) the subject of an advance income ruling previously issued by the Income Tax Rulings Directorate. ...
Ruling

30 November 1995 Ruling 9620343 - XXXXXXXXXX BUTERFLY RULING (NO NEW ISSUES)

To the best of your knowledge and that of the taxpayers involved: (i)none of the issues involved in the requested rulings is being considered by a Tax Services Office or a Taxation Centre in connection with a tax return already filed, and (ii)none of the issues involved in the requested rulings is the subject of any notice of objection or is under appeal. ...
Ruling

30 November 1997 Ruling 9722893 - XXXXXXXXXX BUTTERFLY (SPLIT-UP/GROSS-ASSET)

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

2003 Ruling 2003-0033453 - INTEREST DEDUCTIBILITY QUALIFIED CORPORATION

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, except for the issues, if any, relating to previous loss consolidation transactions described in Paragraphs 28 and 29; (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. ...
Ruling

2004 Ruling 2004-0095491R3 - XXXXXXXXXX

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 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 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 judgment 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. ...
Ruling

2000 Ruling 2000-0056543 - GAAR and 55(3)(a)

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. ...
Ruling

2001 Ruling 2000-0061353 - XXXXXXXXXX

We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in this ruling (i) is in an earlier return of the taxpayer(s) 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(s) or a related person, (iii) is under objection by the taxpayer(s) 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 Revenue Canada or the Canada Customs and Revenue Agency. ...
Ruling

2001 Ruling 2000-0063143 - Butterfly

To the best of your knowledge, none of the issues involved in this ruling: a) is in an earlier tax return of the taxpayers 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 taxpayers or a related person; c) is under objection by the taxpayers 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. ...
Ruling

2001 Ruling 2001-0089523 - XXXXXXXXXX

We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in this ruling (i) is in an earlier return of the taxpayer(s) 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(s) or a related person, (iii) is under objection by the taxpayer(s) 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 Revenue Canada or the Canada Customs and Revenue Agency. ...

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