Search - considered
Results 2631 - 2640 of 3011 for considered
Ruling
2003 Ruling 2003-0046823 - Reverse Estate Freeze
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 the taxpayer 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 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 not expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...
Ruling
2003 Ruling 2002-0169103 - PHANTOM STOCK UNITS
We understand that, to the best of your knowledge and that of the Corporation, none of the issues involved in this ruling request is: (a) in an earlier return of the Corporation or a related person; (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Corporation or a related person; (c) under objection by the Corporation or a related person; (d) before the courts; nor (e) the subject of a ruling previously issued to the Corporation or a related person by the Income Tax Rulings Directorate. ...
Ruling
2003 Ruling 2003-0029633 - Arm's Length Sale of Shares
To the best of your knowledge and that of R and S, none of the issues involved in this ruling request is: (i) in an earlier return of R or S or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of R or S or a related person; (iii) under objection by R or S or a related person; (iv) before the courts; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...
Ruling
2003 Ruling 2003-0044293 - LOSS CONSOLIDATION INTEREST DEDUCTIBILITY
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; (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
2003 Ruling 2003-0038003 - Acquisition of Control
To the best of your knowledge and that of the taxpayers, none of the issues involved in the requested rulings:- is in an earlier return filed by the taxpayer, or a related person;- is being considered by a Tax Services Office or taxation centre in connection with an income tax return previously filed by the taxpayer or a related person;- is subject to a notice of objection under section 165 of the Act or is otherwise under appeal or,- except as disclosed herein, is the subject of a previous ruling. ...
Ruling
2003 Ruling 2003-0037283 - Guarantee Fee 20(i)(e) Treaty Exim Bank
We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in the ruling request: (i) is in an earlier return of any 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 any of the taxpayers or a related person; (iii) is under objection by any of the taxpayers or a related person; or (iv) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...
Ruling
2002 Ruling 2002-0169123 - PHANTOM STOCK UNITS
We understand that, to the best of your knowledge and that of the Corporation, none of the issues involved in this ruling request is: (a) in an earlier return of the Corporation or a related person; (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Corporation or a related person; (c) under objection by the Corporation or a related person; (d) before the courts; nor (e) the subject of a ruling previously issued to the Corporation or a related person by the Income Tax Rulings Directorate. ...
Ruling
2004 Ruling 2003-0053041R3 - Employee Benefit Plan
You advise that to the best of your knowledge and that of the taxpayer referred to above, 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 tax 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, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (v) the subject of a ruling previously issued by the Directorate. ...
Ruling
2004 Ruling 2004-0064771R3 - Prescribed salary deferral arrangement
To the best of your knowledge, and that of the Company, none of the issues involved in the ruling request is: i. in an earlier return of the Company or a related person; ii. being considered by a tax services office or a taxation centre in connection with a tax return already filed by the Company or a related person; iii. under objection by the Company 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 not expired; and v. the subject of a ruling previously issued by the Directorate to the Company or a related person. ...
Ruling
2004 Ruling 2003-0047141R3 - Deferred Bonus Plan - 248(1)(k) SDA
We understand that, to the best of your knowledge and that of the Corporation, none of the issues involved in the ruling request is: (i) in an earlier return of the Corporation or a related person; (ii) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Corporation or a related person; (iii) under objection by the Corporation or a related person; (iv) before the courts; or, (v) the subject of a ruling previously issued by the Directorate to the Corporation or a related person. ...