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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. ...

We understand that, to the best of your knowledge, and that of the taxpayers involved, none of the issues described herein is: (i) in an earlier return of the Partnership, any of the Partners or a related person; (ii) being considered by a Tax Services Office or Taxation Centre in connection with a previously filed return of the Partnership, any of the Partners or a related person; (iii) the subject of any notice of objection; (iv) before the courts or, if a judgment has been issued, the time limit for appeal has not expired; or (v) the subject of a previously issued ruling. ...

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. ...

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 Bidco, Target, Newco II 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 Bidco, Target, Newco II or a related person; (iii) under objection by Bidco, Target, Newco II 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. ...

We understand that, to the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein 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 one of the taxpayers or a related person; (iii) under objection or appeal 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 Canada Revenue Agency (the "CRA"). ...

We understand that, to the best of your knowledge, and that of the taxpayers involved, none of the issues described herein is: (i) in an earlier return of any of the taxpayers or related persons; (ii) being considered by a Tax Services Office or Taxation Centre in connection with a previously filed return of any of the taxpayers or a related person; (iii) the subject of any notice of objection; (iv) before the courts or, if a judgment has been issued, the time limit for appeal has not expired; or (v) the subject of a previously issued ruling. ...

We understand that, to the best of your knowledge, and that of the taxpayers involved, none of the issues described herein is: (i) in an earlier return of any of the taxpayers or related persons; (ii) being considered by a Tax Services Office or Taxation Centre in connection with a previously filed return of any of the taxpayers or a related person; (iii) the subject of any notice of objection; (iv) before the courts or, if a judgment has been issued, the time limit for appeal has not expired; or (v) the subject of a previously issued ruling. ...

We understand that, to the best of your knowledge, and that of the taxpayers involved, none of the issues described herein is: (i) in an earlier return of any of the taxpayers or related persons; (ii) being considered by a Tax Services Office or Taxation Centre in connection with a previously filed return of any of the taxpayers or a related person; (iii) the subject of any notice of objection; (iv) before the courts or, if a judgment has been issued, the time limit for appeal has not expired; or (v) the subject of a previously issued ruling. ...

We understand that, to the best of your knowledge, and that of the taxpayers involved, none of the issues described herein is: (i) in an earlier return of any of the taxpayers or related persons; (ii) being considered by a Tax Services Office or Taxation Centre in connection with a previously filed return of any of the taxpayers or a related person; (iii) the subject of any notice of objection; (iv) before the courts or, if a judgment has been issued, the time limit for appeal has not expired; or (v) the subject of a previously issued ruling. ...

We understand that, to the best of your knowledge, and that of the taxpayers involved, none of the issues described herein is: (i) in an earlier return of any of the taxpayers or related persons; (ii) being considered by a Tax Services Office or Taxation Centre in connection with a previously filed return of any of the taxpayers or a related person; (iii) the subject of any notice of objection; (iv) before the courts or, if a judgment has been issued, the time limit for appeal has not expired; or (v) the subject of a previously issued ruling. ...