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Il a fait les commentaires suivants: «It is my understanding that in those circumstances, that is a part-time personal use of a yacht, the Minister of National Revenue considered that the proper method of evaluating the benefit was by allocating operating costs. ...

You have advised that to the best of the knowledge of the responsible officers of each of the Applicants and yourselves, none of the issues involved in this Ruling: is in an earlier tax return of any of the Applicants or a related person; (i) is being considered by a tax services office or taxation centre in connection with a previously filed tax return or of any of the Applicants or a related person; (ii) is under objection by any of the Applicants or a related person; (iii) is before the courts; or (iv) is the subject of a ruling previously issued by the Income Tax Rulings Directorate of Canada Customs and Revenue Agency ("CCRA") You have advised that to the best of the knowledge of the responsible officers of each of the Applicants, the Proposed Transactions will not have any impact on existing outstanding tax liabilities, if any, of any of the Applicants. ...