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To the best of your knowledge, none of the issues involved in this advance ruling request are being considered by a District Taxation Office or Taxation Centre in connection with a tax return already filed and none of these issues are under objection or appeal. ...

To the best of your knowledge and the knowledge of the University, none of the issues relevant to the ruling being requested is: a) in an earlier return of the University or a related person, b) is being considered by a tax services office or tax centre in connection with a previously filed tax return of the University or a related person, c) under objection by the University or a related person, d) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired, or e) the subject of a ruling previously issued to the University by the Directorate. ...

To the best of your knowledge and the knowledge of XXXXXXXXXX, none of the issues involved in this request for an advance income tax ruling: (a) is in an earlier return of XXXXXXXXXX or of a person related to XXXXXXXXXX; (b) is being considered by a tax services office or taxation centre in connection with a previously filed return of XXXXXXXXXX or of a person related to XXXXXXXXXX; (c) is under objection by XXXXXXXXXX or by a person related to XXXXXXXXXX; (d) is before the courts; or (e) is the subject of a ruling previously issued by the Income Tax Rulings and Interpretations Directorate. ...

To the best of your knowledge, none of the issues involved in this ruling request are: a) in an earlier return of the Employer or a related person, b) being considered by any tax services office or tax centre in connection with a previously filed tax return of the employer or a related person, c) the subject matter of any notice of objection filed pursuant to the Act by the Employer or a related person, d) before the courts, or e) the subject of a ruling previously issued by this Directorate. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues involved in this ruling request: (a) 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, (b) is under objection, and (c) is before the courts or, if a judgement has been issued, the time limit for appeal has not expired. ...

To the best of your knowledge and that of the REIT, none of the issues involved in this letter are: a) in an earlier return of the REIT 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 REIT or a related person, c) under objection by the REIT or a related person, d) before the courts, or e) the subject of a ruling previously issued by the Directorate in respect of the REIT or a related person. ...

To the best of your knowledge, and that of the taxpayer, none of the issues involved in the ruling request is: (i) involved 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 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 and there is no judgment that has been issued in which the time limit for appeal to a higher court has not expired; and (v) the subject of a ruling previously issued by the Income Tax Rulings and Interpretations Directorate. ...

If you are considering these issues in connection with specific transactions, you may wish to submit a request for an advance income tax ruling in the manner set out in Information Circular 70-6R3, Advance Income Tax Rulings. ...

Nevertheless, we offer the following general comments in connection with your request. ...

We understand that, to the best of your knowledge and that of the Company, none of the issues involved in the ruling request (i) is in an earlier return of the Company or a related person, (ii) is being considered by a tax services office or tax centre in connection with a previously filed tax return of the Company or a related person, (iii) is under objection by the Company 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. ...