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You have advised that to the best of your knowledge and that of the taxpayers involved none of the issues involved in this ruling request: (a) is involved in an earlier return of the taxpayer or a related person, (b) is being considered by a tax services office or taxation centre in connection with a tax return already filed by the taxpayer or a related person, (c) is under objection, and (d) is before the courts or, if a judgement has been issued, the time limit for appeal has not expired. ...

However, we have not considered this issue in detail, as we do not have enough information to do so. ...

The issue of whether the use of the realization method or the mark-to-market method is appropriate for reporting derivative income is one that this Directorate has considered before but in the context of mutual fund trusts. ...

To the best of your knowledge and the knowledge of the Corporation, none of the issues involved in this request for an advance income tax ruling: (a) is in an earlier return of the Corporation or of a person related to the Corporation; (b) is being considered by a tax services office or tax centre in connection with a previously-filed return of the Corporation or of a person related to the Corporation; (c) is under objection by the Corporation or by a person related to the Corporation; (d) is before the courts; or (e) is the subject of a ruling previously issued by the Income Tax Rulings and Interpretations Directorate to the Corporation. ...

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 the taxpayers or any 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 any person related to any of the taxpayers, (iii) is under objection by any of the taxpayers or any person related to any of the taxpayers, (iv) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired, and (v) is the subject of a ruling previously issued by the Directorate. ...

They considered the rental operation a business and deducted the losses, accordingly. ...

To the best of your knowledge and that of the Corporation none of the issues in respect of which rulings are herein requested are: (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, (c) under objection by the Corporation 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, and (e) the subject of a ruling previously issued by the Directorate. ...

Paragraph 6 of IT-292, however, allows an amount to be considered an allowance when a deeming provision exists in the provincial Municipal Act, even though the local by-laws may require another allocation of salary. ...

Typically, inventory is considered to consist of the stock of goods that a business holds for resale. ...

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 taxation services office or a taxation centre in connection with a tax return already filed, or is under objection or appeal. ...