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To the best of your knowledge and that of your client, none of the issues involved in the ruling request is: in an earlier return of your client or a related person, being considered by a tax services office or taxation center in connection with a previously filed tax return of your client or a related person, under objection by your client or a related person, before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired, or the subject of a ruling previously considered by the Directorate in respect of your client or a related person other than advance income tax ruling 2000-0041683. ...

To the best of your knowledge and that of the Taxpayers, none of the issues involved with this request: (a) is involved in an earlier return of the Taxpayers or a related person: (b) is being considered by a tax services office or a taxation centre in connection with a tax return already filed by the Taxpayers or a related person; (c) is under objection by the Taxpayers or a related person; (d) is before the courts or, if a judgment has been issued, the time limit for appeal has not expired; or (e) is the subject of a ruling previously considered by this Directorate, with the exception of the ruling no. 2007-024199 issued to XXXXXXXXXX. ...

However, by virtue of the "available for use rules" found in subsections 13(26) to (31) of the Act, CCA for a Class 43.1 or 43.2 property that has been acquired and which is not considered available for use at the end of a taxation year may be restricted until such time as the property is available for use. ... In addition, examples of what could be considered a structural change include, the conversion of the front half of a house into a store, the conversion of a portion of a house into a self-contained domestic establishment for earning rental income (a duplex, triplex, etc.), and alterations to a house to accommodate separate business premises. ...

Given the fact that XXXXXXXXXX he is considered to be a member of the clergy and therefore meets the status test for the purpose of deduction pursuant to paragraph 8(1)(c). ... Function Test The function test only needs to be considered in respect of the one employee who is a XXXXXXXXXX, since he has met the status test by virtue of being a member of a clergy. ...

To the best of your knowledge and that of the above-referenced taxpayer, none of the issues involved in this ruling is: (i) in an earlier return of the above-referenced 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 above-referenced taxpayer or a related person; (iii) under objection by the above-referenced taxpayer or a related person; (iv) before the courts; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... The Shareholders who receive the Fund Units as described in paragraph 10 above will be considered to have acquired them at a cost equal to their fair market value at the time of the Capital Reduction. ...

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 a tax centre in connection with a tax return already filed by 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; and v. the subject of a ruling previously issued by the Directorate to the Taxpayer or a related person. ... Any income or other additional amounts in the Trust Account that may reasonably be considered to have accrued to or for the benefit of a Participant to the end of a calendar year will be paid to the Participant in that same calendar year, net of any required statutory withholdings. ...

If in fact the monthly payments received by the taxpayer are non-refundable in the event that the sale does not transpire then the amounts received by the taxpayer will likely be considered rental income. ... If your daughter's monthly payments are intended as payments for her right to use the property, are non-refundable, and represent the fair market rent for the property, they would likely be considered rental income (i.e., your property continues to be a rental property) and, in that case, your expenses incurred for the purpose of earning the rental income would generally be deductible for the purpose of computing income for tax purposes. ...

To the best of your knowledge and that of your client, none of the issues involved in the ruling request is: in an earlier return of your client or a related person, being considered by a tax services office or taxation center in connection with a previously filed tax return of your client or a related person, under objection by your client or a related person, before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired, or the subject of a ruling previously considered by the Directorate in respect of your client or a related person. ...

To the best of your knowledge and that of the Taxpayers, none of the issues involved with this request: (i) is involved in an earlier return of the Taxpayers or a related person: (ii) is being considered by a tax services office or a taxation centre in connection with a tax return already filed by the Taxpayers or a related person; (iii) is under objection by the Taxpayers or a related person; (iv) is before the courts or, if a judgment has been issued, the time limit for appeal has not expired; or (v) the subject of a ruling previously considered by this Directorate. ...

To the best of your knowledge and that of the taxpayer involved, none of the issues contained in this ruling request 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 of the Canada Revenue Agency ("CRA") 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 to the taxpayer 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. ... Each holder of XXXXXXXXXX Shares is considered a member of ACo within the meaning of subsection 137(4.1) of the Act. ...