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2014 Ruling 2014-0529291R3 F- Use of a trust by a charitable organization CRA Tags 245(2) 149.1(2)(a) Principales Questions: 1.Whether the proposed transactions, in and of themselves, would be considered activities that would constitute the carrying on a business that is not a related business of the Charitable Organization for the purposes of paragraph 149.1(2)a)? ...

To the best of your knowledge and that of the Taxpayers, none of the issues involved in the ruling request is: i. in an earlier return of any of the Taxpayers or a related person; ii. being considered by a tax services office or a tax centre in connection with a tax return already filed by any of the Taxpayers or a related person; iii. under objection by any of 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; and v. the subject of a ruling previously issued by the Directorate to any of the Taxpayers or a related person. ...

2016 Ruling 2015-0605851R3 F- Partners creating professional corporation CRA Tags 125(7) 103(1) 245 Principales Questions: Will the fees earned by a professional corporation created by a partner in order to provide professional services to a partnership, as an independent contractor, be considered to be specified partnership income? ...

You have advised us that to the best of your knowledge and that of the taxpayers involved, none of the issues contained in this advance income tax ruling is: (a) dealt with in an earlier tax return of any of the taxpayers or a related person; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of any of the taxpayers or a related person; (c) under objection by any of the taxpayers or a related person; (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (e) the subject of an advance income tax ruling previously issued by the Directorate. ...

To the best of your knowledge, and that of the above-noted taxpayer, none of the issues involved in this advance income tax ruling are: (i) in an earlier tax return of the above-noted taxpayer or of a related person; (ii) being considered by a Tax Services Office or a Taxation Centre in connection with a previously-filed tax return of the above-noted taxpayer or of a related person; (iii) under objection by the above-noted taxpayer or by 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 to the above-noted taxpayer or a related person. ...

We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling request herein are: (i) dealt with in an earlier return of Aco, Dco, 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 Aco, Dco, or a related person; (iii) under objection by Aco, Dco, or a related person; (iv) the subject of a previous ruling issued by the Income Tax Rulings Directorate to Aco, Dco, or a related person; nor (v) before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

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 persons related to the taxpayer; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or persons related to the taxpayer; (iii) under objection by the taxpayer or persons related to the taxpayer; (iv) before the courts; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

To the best of your knowledge and that of the taxpayers, none of the issues involved in this advance income tax ruling is: (i) dealt with in an earlier return of the taxpayers or a person related to the taxpayers; (ii) being considered by any tax services office or taxation centre in connection with a tax return previously filed by the taxpayers or a person related to the taxpayers; (iii) under objection by the taxpayers or by a person related to the taxpayers; (iv) the subject of a previously issued ruling 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 expired. ...

To the best of your knowledge and that of the parties identified above, none of the issues raised in this ruling request are (a) in an earlier return of any of the parties or a related person, (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of any of the parties or a related person, (c) under objection by any of the parties or a related person, (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired, or (e) the subject of a ruling previously issued to any of the parties or a related person by the Income Tax Rulings Directorate of the Canada Revenue Agency. ...

To the best of your knowledge, and that of the Corporation, SisterCo, SubCo, Partnership 1 and Partnership 2 none of the issues in this ruling request is: (i) involved in an earlier return of the Corporation, SisterCo, SubCo, Partnership 1, Partnership 2 or any related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the Corporation, SisterCo, SubCo or a related person; (iii) under objection by the Corporation, SisterCo, SubCo or a related person; (iv) before the courts; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate of the Canada Revenue Agency, to the Corporation, SisterCo, SubCo, Partnership 1, Partnership 2 or related persons. ...