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To the best of your knowledge and that of the above-referenced taxpayers, none of the issues involved in this ruling is: (i) dealt with in an earlier return of any of the above referenced 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 any of the above-referenced taxpayers or a related person, (iii) under objection or appeal by any of the above-referenced taxpayers, or a related person, or (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

Placer Dome Canada Limited, 2006 SCC 20) have confirmed that whether an activity constitutes hedging depends on sufficient inter-connection or integration with the underlying transaction. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling is: (a) in a previously filed income tax return of any of the taxpayers or a related person; being considered by a Tax Services Office or a tax centre in connection with a previously filed income tax return of any of the taxpayers or a related person; (b) under objection by any of the taxpayers or a related person; (c) before the courts; or (d) the subject of a ruling previously issued by the Income Tax Rulings Directorate involving any of the taxpayers or a related person. ...

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; or v. the subject of a ruling previously issued by the Directorate to any of the Taxpayers or a related person (XXXXXXXXXX). ...

We understand that to the best of your knowledge and that of the taxpayers involved none of the issues involved in the requested ruling is: (i) in an earlier return of a taxpayer identified in this document or of a related person; (ii) being considered by any Tax Services Office or Taxation Centre of the Canada Revenue Agency (“CRA”) in connection with a tax return already filed; (iii) under objection by a taxpayer identified in this document 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 not expired; or (v) the subject of a previously issued ruling. ...

To the best of your knowledge and that of the Partnership and the Named Partners (collectively the "Taxpayers"), none of the issues involved in the ruling request is: i. in an earlier return of one 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 one of the Taxpayers or a related person; iii. under objection by one 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 one of the Taxpayers or a related person. ...

To the best of your knowledge and that of the Partnership and the Partners (collectively the "Taxpayers"), none of the issues involved in the ruling request is: i. in an earlier return of one 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 one of the Taxpayers or a related person; iii. under objection by one 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 one of the Taxpayers or a related person. ...

To the best of your knowledge and that of the Partnership and the Named Partners (collectively the "Taxpayers"), none of the issues involved in the ruling request is: i. in an earlier return of one 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 one of the Taxpayers or a related person; iii. under objection by one 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 one of the Taxpayers or a related person. ...

To the best of your knowledge and that of the Partnership and the Named Partners (collectively the "Taxpayers"), none of the issues involved in the ruling request is: i. in an earlier return of one 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 one of the Taxpayers or a related person; iii. under objection by one 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 one of the Taxpayers or a related person. ...

To the best of your knowledge and that of the above-referenced taxpayers, none of the issues involved in this ruling is: (a) in an earlier return of the above-referenced 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 the above-referenced taxpayers or a related person; (c) under objection by the above-referenced taxpayers or a related person; (d) before the courts; or (e) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...