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To the best of your knowledge, and that of the parties to this ruling, none of the issues contained in this advance income tax ruling: is in an earlier return of the taxpayer or a related person, is being considered by a tax services office or a taxation centre in connection with a previously filed tax return of the taxpayer or a related person, is under objection by the taxpayer or related person, is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired, or is the subject of a ruling previously issued by the Directorate. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein: (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 before the courts or, if a judgement 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 Directorate. ...

The LLC may not have established residency in the U.S. where the only connection with the U.S. is that the U.S. is the country under whose laws it was formed and the location of the annual meeting of the board of directors. ...

We understand that to the best of your knowledge and that of the taxpayers involved none of the issues involved in the requested rulings is being considered by a tax services office or a taxation centre in connection with a tax return already filed, or is under objection or appeal. ...

To the best of your knowledge, and that of the parties to this ruling, none of the issues contained in this advance income tax ruling: 1. is in an earlier return of the taxpayer or a related person; 2. is being considered by a tax services office or a taxation centre in connection with a previously filed tax return of the taxpayer or a related person, 3. is under objection by the taxpayer or related person, 4. is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired, or 5. is the subject of a ruling previously issued by the Directorate. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (i) dealt with 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) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein: (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; and (iv) is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (i) dealt with 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) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not 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 (e) the subject of a ruling previously issued by this Directorate to the taxpayers or related persons with the exception of ruling 3-4150. ...

We understand that to the best of your knowledge and that of the taxpayers involved, none of the issues involved in this advance ruling request is being considered by a Tax Services Office or a Taxation Centre in connection with a tax return already filed and none of the issues is under objection or appeal. ...