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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 Profitco, Lossco 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 Profitco, Lossco or a related person; (iii) under objection by Profitco, Lossco or a related person; (iv) the subject of a previous ruling issued by the Income Tax Rulings Directorate to the taxpayers 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 that to the best of your knowledge and that of the Partnership and the Partners (collectively "the Taxpayers"), none of the issues involved in this Ruling is: (i) in an earlier return of the Taxpayers 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 expired; 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 Partnership and the Electing 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. ...

You have advised that to the best of your knowledge, and that of the taxpayers involved, none of the issues contained involved in this advance income tax ruling is: in an earlier return of the taxpayers, or a related person; being considered or under assessment by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or a related person; under objection by the taxpayers or a related person; before the courts, and no judgement has been issued which may be under appeal; or the subject of a ruling previously issued by the Directorate. ...

We understand that to the best of your knowledge and that of the taxpayers on whose behalf this ruling is being requested, none of the issues involved in this ruling request: (i) is in an earlier return of the taxpayers or a related person; (ii) is 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) is under objection by the taxpayers or a related person; (iv) is, in relation to the taxpayers or a related person, before the courts or is the subject of a judgment the time limit for appeal from which has not expired; or (v) is the subject of a ruling previously considered by the Canada Revenue Agency in relation to the taxpayers or a related person. ...

To the best of your knowledge and that of the Partnership and the Electing 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. ...

We understand that to the best of your knowledge and the Named Partners (collectively the "Taxpayers"), none of the issues involved in this 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 taxation centre in connection with a tax return previously 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; or (v) the subject of a previously issued ruling by the Directorate to one of the Taxpayers or a related person. ...

We understand that, 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 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) before the courts, or (v) the subject of a ruling previously issued by the Directorate to the taxpayers or a related person. ...

We understand that to the best of your knowledge and that of the Partnership and the Partners (collectively the "Taxpayers"), none of the issues involved in this ruling request: (i) is in an earlier return of one of the Taxpayers or a related person; (ii) is being considered by a tax services office or taxation centre in connection with a tax return previously filed by any of the Taxpayers or a related person; (iii) is under objection by any of the Taxpayers or a related person; (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 considered 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. ...