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To the best of your knowledge and that of the taxpayers involved in this ruling request, 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. ...

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. ...

In connection with the winding-up; 17. Subparagraph 31(vii) of the Ruling Letter is replaced by: DC3 will distribute to Newco 4 the Sub-Newco 4 Note; 18. ...

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 a 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. ...

We understand that to the best of the knowledge of the taxpayers involved and XXXXXXXXXX, none of the issues involved in the ruling request: (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 judgment has been issued, the time limit for appeal to a higher court has not expired, or (v) is the subject of a ruling previously issued by the Rulings Directorate. ...

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 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 a 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 this Directorate. ...

To the best of your knowledge and that of the Corporation none of the issues in respect of which rulings are herein requested are: a) in an earlier return of the Corporation or a related person, b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Corporation, c) under objection by the Corporation 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 Directorate. ...

To the best of your knowledge and that of the Corporation none of the issues in respect of which rulings are herein requested are: (a) in an earlier return of the Corporation or a related person, (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Corporation, (c) under objection by the Corporation 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 Directorate. ...

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

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