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Income and other taxes receivable (excluding HST/GST/PST/QST) that relate to taxation years for which a return has not been filed will not be considered property. 118. ... In such case, any such payments made by Canadian DC to Canadian TC will be considered to be part of the First Distribution, as described in Paragraph 120, made by Canadian DC to Canadian TC. ... Following the set-off, each such note will be considered to be paid in full and will be cancelled. 127. ...

(ii) Whether a benefit is considered to have been conferred on a minority interest owner, who is a wholly-owned subsidiary of the taxpayer, of FA2 as a result of the transfer described in (i) above? ... Korean Opco is considered to be a corporation for the purposes of the Act. ... Hungarian LLC is considered to be a corporation for the purposes of the Act. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues involved in this request are being considered by a Tax Services Office or a Taxation Centre in connection with a tax return already filed, and none of the issues are under appeal or objection. ... The Facilities described in subparagraphs 7(a) to (i) above that are not buildings, and the Miscellaneous Interests will not be considered "rental property" of the Trust within the meaning of Regulation 1100(14) in respect of a taxation year. ... The Facilities and the Miscellaneous Interests will not be considered as "foreign property" within the meaning of that term under subsection 206(1) of the Act. ...

You have advised us that to the best of your knowledge and that of the taxpayer involved none of the issues involved in this ruling request: (a) is in an earlier return of the taxpayer or a related person; (b) is being considered by a tax services office ("TSO") or taxation centre in connection with a previously filed tax return of the taxpayer or a related person; (c) is under objection by the taxpayer 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 Directorate. ... For the purposes only of applying paragraph 88(1)(c) to determine the cost of the Target Partnership A Units that were owned by TargetSubA on the Take-Up Date, following the amalgamation described in paragraph 17 above, pursuant to subsection 88(4), (i) Target Amalco will be considered to be the same corporation as, and a continuation of, Target, for the purposes of applying the reference in subparagraph 88(1)(c.4)(iii) to "the subsidiary"; and (ii) Target Amalco will be considered to be the same corporation as, and a continuation of, TargetSubA, for the purposes of determining whether Target Partnership A Units were capital property owned by Target Amalco on the Take-Up Date, and for the purposes of determining when AcquisitionCo last acquired control of Target Amalco. ... For the purposes only of applying paragraph 88(1)(c) to determine the cost of the Target Partnership A Units that were owned by TargetSubA on the Take-Up Date, following the amalgamation described in paragraph 18 above, pursuant to subsection 88(4), (iii) New Amalco will be considered to be the same corporation as, and a continuation of, Target, for the purposes of applying the reference in subparagraph 88(1)(c.4)(iii) to "the subsidiary"; and (iv) New Amalco will be considered to be the same corporation as, and a continuation of, TargetSubA, for the purposes of determining whether Target Partnership A Units were capital property owned by New Amalco on the Take-Up Date, and for the purposes of determining when AcquisitionCo last acquired control of New Amalco. ...

Reasons: Based on the opinion of NRCan, the expenses will not be considered to be related to a potential or actual extension of an existing mine that has come into production in reasonable commercial quantities. ... To the best of the knowledge of the Company, none of the issues contained in this ruling request is: (a) in a previously filed tax return of the Company or a related person; (b) being considered by a tax services office or a tax centre in connection with a previously filed tax return of the Company or a related person; (c) under objection by the Company or a related person; (d) the subject of a current or completed court process involving the Company or a related person; or (e) the subject of a ruling request previously considered by the Income Tax Rulings Directorate. ... An expense incurred by the Company, after the date of this letter, in respect of the exploration program in the New Zones described in the Proposed Transactions that will be undertaken at depths below the existing Open Pit Mines with a ramp starting at the bottom of the Open Pit Mines, will not be considered to be related to a potential or actual extension of the Open Pit Mines for the purposes of subparagraph (f)(vi) of the definition of CEE in subsection 66.1(6), provided that, if such exploration program culminates in the development of a mining operation, any such operation is conducted utilizing a new underground mine rather than an extension of any of the Open Pit Mines. ...

Will each episode in a television series be considered to be a property in and by itself, or is the entire series considered to be one single property? ... Each episode is considered to be a separate property. Reasons: 1. In this fact situation, the distributor is a qualified corporation therefore it is not an investor and subsection 125.4(4) of the Act does not apply. ... We also considered the definition of excluded production in subsection 1106(1) of the Regulations. ...

HST/GST/PST/QST receivable that relates to reporting periods ending after the Distribution or to reporting periods for which a return has not been filed will not be considered property. 62. ... For greater certainty, for the purposes of these determinations: c) no amount will be considered to be a liability unless it represents a legal liability which is capable of quantification. ... Following the set-off, each such note will be considered to be paid in full and will be cancelled. ...

The words "(or the amount ultimately considered to be the agreed amount)" are added in paragraph (b) after the words "agreed amount" and before the words "referred to". 9- Paragraphs (a) and (b) of ruling Q are replaced by the following: (a) the amount included in A of the definition of the "cumulative eligible capital" in respect of Operating LP by virtue of the acquisition of the CCo Operating Assets (other than the CCo Provincial Operating Assets previously transferred) as described in paragraph 63 will be equal to 3/4 of the agreed amount (or the amount ultimately considered to be the agreed amount) referred to in Paragraph 63 in respect of the eligible capital property included in such CCo Operating Assets; (b) the amount included in paragraph (a) of E of the definition of the "cumulative eligible capital" in respect of Operating LP by virtue of the disposition of the DCo Amalco Non-Operating Assets as described in paragraph 63 will be equal to the fair market value of the eligible capital property included in such DCo Amalco Non-Operating Assets (3/4 of which will be included in amount E of the definition of "cumulative eligible capital"); and Notwithstanding the above-mentioned changes, we confirm that the rulings given in the Ruling, as amended above, will continue to be binding on the Canada Revenue Agency in the manner described therein. ...

2006 Ruling 2006-0217661R3- Qualified Investment Unedited CRA Tags 204 212(1)(b)(ii)(C) XXXXXXXXXX Principal Issues: Will a particular bond be considered a qualified investment for purposes of the rules governing registered retirement savings plans (RRSP) under the Income Tax Act? ... 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. ...

OTHER INFORMATION 8.To the best of the Employee's and Employer's knowledge none of the issues involved in this ruling request is being considered by a taxation services office or tax centre in connection with any tax returns filed and none of the issues is under objection or appeal. ... C.The full amount of the retiring allowance will be deductible in determining the income of the Employer for its taxation year ending XXXXXXXXXX, and will be considered reasonable for the purpose of section 67 of the Act. ...