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You have advised us that to the best of your knowledge and that of the taxpayer involved none of the issues involved in this ruling request are: (i) in an earlier return of any of the taxpayer or a related person; (ii) being considered by a tax services office ("TSO") or taxation centre ("TC") in connection with a previously filed tax return of any of the taxpayer or a related person; (iii) under objection by any of the taxpayer 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 Directorate. ... DC has obligations under certain options (collectively the "Existing DC Broker Options" and individually an "Existing DC Broker Option"), whereby in connection with certain previous equity financing transactions, certain brokers involved in such equity financing became entitled to acquire Existing DC Shares at specified exercise prices. ...

We also acknowledge the information provided in subsequent correspondence and during our various telephone conversations (XXXXXXXXXX) in connection with your request. You have advised that to the best of your knowledge, and that of the responsible officers of each of the Applicants, none of the issues involved in this Ruling: (i) is in an earlier tax return of any of the Applicants 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 any of the Applicants or a related person; (ii) is under objection by any of the Applicants or a related person; (iii) is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired; or (iv) is the subject of a ruling previously issued by the Income Tax Rulings Directorate (although the proposed transactions were designed from transactions that were subject to prior advance income tax rulings, in particular, 2002-013308 dated XXXXXXXXXX, 2002). ...

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 a related person; (ii) being considered by a tax services office ("TSO") or taxation centre ("TC") 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, 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. ... In connection with the winding-up of DC2, DC2 will assign and distribute: the Sibling1 Holdco-DC2 Notes and the Sibling1 Holdco-DC2 Redemption Note to Sibling1 Holdco; the Sibling2 Holdco-DC2 Notes and the Sibling 2 Holdco-DC2 Redemption Note to Sibling2 Holdco; and the Sibling3 Holdco-DC2 Notes and the Sibling 3-DC2 Redemption Note to Sibling Holdco3. ...

PRELIMINARY MATTERS To the best of your knowledge and that of the responsible officers of the above-mentioned taxpayers, none of the issues raised in this ruling request are: (a) dealt with in a previously filed return of one of the Taxpayers or a related person; (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of one of the Taxpayers or a related person; (c) under objection by one of the Taxpayers or a related person; (d) the subject of a current or completed court process involving one of the Taxpayers or a related person; or (e) the subject of a ruling previously considered by the Income Tax Rulings Directorate. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

To the best of your knowledge and of the knowledge of the taxpayers involved in the Proposed Transactions, none of the issues described in this ruling is: (a) in an earlier tax return of a taxpayer involved or a related person; (b) being considered by a tax services office or taxation centre in connection with any tax return previously filed by a taxpayer involved or a related person; (c) under objection or appeal by a taxpayer involved or a related person; (d) before the courts in any Canadian jurisdiction and no judgment has been issued which may be under appeal; or (e) the subject of a ruling previously issued to a taxpayer involved or a related person. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

We acknowledge our telephone conversations in connection herewith. To the best of your knowledge, and that of the taxpayers named herein, none of the issues involved in this advance income tax ruling request is under objection or appeal or is being considered by any tax services office or taxation centre of Revenue Canada in connection with any income tax return already filed. ...

However, the following facts are usually set out in connection with requests for advance rulings: (i) the name of the producer, who must be a Canadian; (ii) the names of any corporations set up by the producer to produce the film, whether or not they are Canadian, and the names and nationalities of the shareholders and directors; (iii) the involvement of non-Canadians and their explicit role. ... Budget In connection with a ruling request, the Budget for the film will be reviewed. ...

You have advised that to the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (a) in an earlier return of any of the taxpayers or a related person; (b) 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; (c) under objection by any of the taxpayers or a related person; (d) the subject of a ruling previously issued by the Income Tax Rulings Directorate; or (e) before the Courts. ... The amount shall be designated pursuant to the resolution of the directors of Transferee1, Transferee2, Tranferee3, Transferee4 and Transferee5, as the case may be, made in connection with the issuance of such share. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in this 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 taxation centre in connection with a previously filed tax return of 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 expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... Each of the DC Class A Preference Shares will have the following attributes: (a) will be non-voting and non-participating; (b) will be redeemable and retractable, subject to applicable law, at any time for an amount equal to the amount determined by dividing the aggregate FMV of the property received by the corporation on the issuance of the Class A Preference Shares, less the aggregate FMV of any non-share consideration issued or liabilities assumed by the corporation in connection with the issuance of such shares, by the number of the Class A Preference Shares issued ("DC Class A Redemption Amount"); (c) will be entitled to a fixed, preferential, non-cumulative monthly dividend of XXXXXXXXXX % of the DC Class A Redemption Amount, and (d) will rank in first priority over all other classes on dissolution. 10. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in this 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 taxation centre in connection with a previously filed tax return of 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 expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... In connection with the winding-up of DC2, DC2 will distribute to each of TC1, TC2 and TC3 the particular Redemption Note owing by it to DC2. ...