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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. ...

For the purposes of determining whether a person is to be considered financially dependent on the annuitant of an RRSP, the definition of refund of premiums provides that it is assumed that, unless the contrary is established, a dependent is not financially dependent on the annuitant for support at the time of the annuitant's death if the income of the dependent for the taxation year immediately preceding the year in which the annuitant died exceeded the amount in paragraph 118(1)(c). ... The Department has not addressed what is required to be considered dependent by reason of physical or mental infirmity for the purposes of clause 60(l)(v)(B) of the Act. ...

Principal Issues: Would an amount be considered reasonable retiring allowance Position: Yes, the amount not exceeding an amount eligible for rollover under paragraph 60(j.1) of the Act to an RRSP would generally be accepted as reasonable. ... To the best of your knowledge, none of the issues involved in this ruling are being considered by a Tax Services Office or Taxation Centre in connection with a tax return already filed, and none of the issues are under objection or appeal. ...

Reasons: The XXXXXXXXXX programs would be considered a related business for purposes of subsection 149.1(2) of the Act. ... We understand that to the best of your knowledge and that of the taxpayers involved, none of the issues involved in the requested rulings is being considered by a District Taxation Office or a Taxation Centre in connection with a tax return already filed, and none of the issues involved in the requested rulings is the subject of any notice of objection or is under appeal. ...

We understand that 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 an office of Revenue Canada 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. ... A.XXXXXXXXXX will not be considered to have received any proceeds of disposition for the purposes of subsection 106(2) of the Act as a result of executing partial releases or surrenders of XXXXXXXXXX income interest in each of the Trusts. ...

In furtherance of this request, you have noted that, (i) the tax account number of XXXXXXXXXX (ii)the tax account number of XXXXXXXXXX (iii)the corporations file their returns of income at the XXXXXXXXXX Taxation Centre and, (iv)that, to the best of the knowledge of responsible officials of the corporations, none of the issues being considered in the context of this advance income tax ruling are being considered by a District Tax Services Office in connection with an income tax return previously filed nor has a Notice of Objection been filed with respect to any of those issues. ...

You have advised us that to the best of your client's knowledge, none of the issues involved herein are being considered by a Tax Services Office or Taxation Centre of Revenue Canada in connection with a tax return already filed and that none of the issues are under objection or appeal. ... The amount of $XXXXXXXXXX will be deductible by the employer in computing his income from the business of farming for the year in which it is paid and will be considered reasonable for the purposes of section 67 of the Act. ...

To the best of your knowledge and the knowledge of the taxpayers, none of the issues involved in this request for an advance income tax ruling: (a) is in an earlier 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 return of the taxpayers or of a person related to either of the taxpayers; (c) is under objection by the taxpayers or by a person related to either of the taxpayers; (d) is before the courts; (e) is the subject of a ruling previously considered by the Income Tax Rulings Directorate. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein are: (i) dealt with 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) 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 Given Provided that the above statements constitute a complete and accurate disclosure of all the relevant facts, proposed transactions, and purpose of the proposed transactions and provided further that all the proposed transactions are completed as described above, we confirm the following: XXXXXXXXXX will be considered to be an association organized exclusively for a purpose other than profit with no part of its income payable to or otherwise available for the personal benefit of any member XXXXXXXXXX so that, in any year in which it, in fact, operates on such basis, XXXXXXXXXX will qualify as a non-profit organization as described in paragraph 149(1)(l) and will, accordingly, be exempt from tax under Part I of the Act on its taxable income for that year. ...

The requirement to provide XXXXXXXXXX can be considered a service for purposes of paragraph 20(1)(m)(i) XXXXXXXXXX XXXXXXXXXX 3-992401 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 1999 Dear Sirs: Re: Advance Income Tax Ruling Request XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX requesting an advance income tax ruling on behalf of the above named taxpayer. We understand that, to the best of your knowledge, none of the issues raised in this ruling is being considered by a Taxation Services Office or Taxation Centre in connection with an income tax return already filed, is the subject of any notice of objection or is under appeal. ...