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We understand that, to the best of your knowledge, none of the issues involved in the ruling request: (i) is in an earlier return of the taxpayer 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 taxpayer or a related person, (iii) is under objection or appeal by the taxpayer 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 issued by the Canada Revenue Agency. ...

is being considered by any tax services office or taxation centre of the Canada Revenue Agency (the "CRA") in connection with any income tax return already filed, or? ...

To the best of your knowledge, and that of the taxpayer, none of the issues involved in this advance ruling is:- dealt with in an earlier return of the taxpayer or a related person;- being considered by a tax services office or a taxation centre in connection with a tax return already filed;- under objection by the taxpayer or a related person; or- before the courts. ...

In this regard, our view is that if the distance travelled by the automobile is primarily in connection with the partnership's business activities, it would be travelled primarily in the course of Manco's business activities. ...

To the best of your knowledge and that of the taxpayers, none of the issues in this ruling request is: (i) involved in an earlier return of any 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 any of the taxpayers or a related person; (iii) under objection by any of the taxpayers or a related person; or (iv) before the courts. ...

You have advised us that to the best of your knowledge and that of the taxpayers involved none of the issues involved in this ruling request are: (i) in an earlier return of the taxpayers or related persons; (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 related persons; (iii) under objection by the taxpayers or related persons; (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. ...

Paragraph 42.1 is added and states that: "In order to provide greater assurance that funds will be available to satisfy the indemnification obligations of the Vendors with respect to certain representations and warranties made by the Vendors in connection with the sale of the shares of Holdings and the Offering of the Class A Units, escrow arrangements will be established pursuant to which a total of $XXXXXXXXXX of cash will be deposited with an escrow agent to be held for up to XXXXXXXXXX years following the Offering. ...

We understand that to the best of your knowledge and that of the taxpayer involved, none of the issues contained herein: (i) is in an earlier tax return of the taxpayer 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 taxpayer or a related person; (iii) is under objection by the taxpayer or a related person; (iv) is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired; or (v) is the subject of an advance income tax ruling previously issued by the Income Tax Rulings Directorate. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling request are: (i) dealt with in an earlier return of the taxpayers or related persons; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or related persons; (iii) under objection by the taxpayers or related persons; (iv) subject to a ruling previously issued by the Income Tax Rulings Directorate; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

We acknowledge the additional information received on XXXXXXXXXX To the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling request are: (i) dealt with in an earlier tax return of A Co or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of A Co or a related person; (iii) under objection by the A Co 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 and Interpretation Directorate of the Canada Revenue Agency ("CRA"). ...