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To the best of your knowledge and that of the taxpayers involved, none of the issues involved in this ruling (i) is in an earlier return of the taxpayer(s) 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(s) or a related person, (iii) is under objection by the taxpayer(s) 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 Revenue Canada or the Canada Customs and Revenue Agency (the "CCRA"). ...

To the best of your knowledge and that of the taxpayers involved in this ruling request, none of the issues contained herein is: (a) dealt with in an earlier return of the taxpayer(s) 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 taxpayer(s) or a related person, (c) under objection by the taxpayer(s) or a related person, (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired, and (e) 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 the taxpayers involved, none of the issues involved in the ruling request: (i) is in an earlier return of a taxpayer or a related person, (ii) is being considered by a tax services office or taxation center in connection with a previously filed tax return of a taxpayer or a related person, (iii) is under objection by a 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 Directorate. ...

We understand that, to the best of your knowledge and that of the taxpayer involved, 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 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 Revenue Canada or the Canada Customs and Revenue Agency ("CCRA"). ...

To the best of your knowledge and that of the taxpayers involved, none of the issues involved in this ruling (a) is in an earlier return of the taxpayer(s) or a related person, (b) is being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer(s) or a related person, (c) is under objection by the taxpayer(s) or a related person, (d) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired, and (e) is the subject of a ruling previously issued by Revenue Canada or CCRA. ...

You have been advised by your clients that to the best of their knowledge, none of the issues involved in this ruling: (i) is in an earlier return; (ii) is being considered by a tax services office or taxation center in connection with a previously filed tax return; (iii) is under objection; (iv) is before the courts; or (v) is the subject of a previously issued ruling. ...

You have been advised by your clients that to the best of their knowledge, none of the issues involved in this ruling request: (i) is in an earlier return; (ii) is being considered by a tax services office or taxation centre in connection with a previously filed tax return; (iii) is under objection; (iv) is before the courts; or (v) is the subject of a previously issued ruling. ...

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 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) 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 not expired. ...

To the best of your knowledge, and that of any of the taxpayers, none of the issues involved 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; (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 the taxpayers on whose behalf this ruling is requested, none of the issues involved in this advance income tax ruling are: (i) contained in earlier returns 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 the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) before the courts or, if a judgement 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 taxpayers or a related person. ...