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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: (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. ...

You have advised us that to the best of your knowledge and that of the Taxpayers, none of the issues involved in this ruling request are: (i) in an earlier return of the Taxpayers or persons related to the Taxpayers; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the Taxpayers or persons related to the Taxpayers; (iii) under objection by the Taxpayers or persons related to the Taxpayers; (iv) before the courts; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

We understand that, to the best of your knowledge and that of Pubco, none of the issues in this Ruling Letter: (i) is in an earlier return of Pubco 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 Pubco or a related person; (iii) is under objection by Pubco or a related person; (iv) is before the courts or, if a judgement has been issued, the time limit for appeal has not expired; or (v) is the subject of a Ruling previously issued by the Directorate after XXXXXXXXXX. ...

We understand that, to the best of your knowledge and that of the taxpayer, none of the issues involved in the ruling request is: (i) in a previously filed return of the taxpayer or of a related person; (ii) being considered by a tax services office or tax centre 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) the subject of a current or completed court process involving the taxpayer or a related person; or (v) the subject of a ruling request previously considered by the Income Tax Rulings Directorate. ...

We understand that, to the best of your knowledge and that of Parent, Subsidiary, Newco and Lossco involved, none of the issues contained in this ruling request herein is: (i) dealt with in an earlier return of Parent, Subsidiary, Lossco, Newco 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 Parent, Subsidiary, Lossco, Newco or a related person; (iii) under objection by Parent, Subsidiary, Lossco, Newco or a related person; (iv) the subject of a previous ruling issued by the Income Tax Rulings Directorate to Parent, Subsidiary, Newco, Lossco 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. ...

We understand that to the best of your knowledge, and that of the taxpayers involved, none of the matters considered in this ruling request are: a) in an earlier return of the taxpayers or related persons; b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the taxpayers or related persons; c) under objection by the taxpayers or related persons; 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 a ruling previously issued by this Directorate to the taxpayers or related persons. ...

XXXXXXXXXX 2007-024605 XXXXXXXXXX, 2008 Dear XXXXXXXXXX: Re: Advance Tax Ruling: XXXXXXXXXX (the "Partnership") and XXXXXXXXXX (the "Named Partners") We understand that to the best of your knowledge, and that of the Partnership and Named Partners (collectively, the "Taxpayers") involved, 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 taxation centre in connection with a previously filed tax return of one or any of the Taxpayers or a related person; (iii) under objection by one or 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 Income Tax Rulings Directorate to one of the Taxpayers or a related person. ...

We understand that to the best of your knowledge, and that of the Partnership and Named Partners (collectively, the "Taxpayers") involved, 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 taxation centre in connection with a previously filed tax return of one or any of the Taxpayers or a related person; (iii) under objection by one or 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 Income Tax Rulings Directorate to one of the Taxpayers or a related person. ...

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

To the best of your knowledge and that of the Partnership and the Named Partner (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. ...