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To the best of your knowledge and that of the Taxpayers involved, none of the issues involved with this request: (i) is involved in an earlier return of the Taxpayers or a related person; (ii) is being considered by a tax services office or a taxation centre in connection with a tax return filed by the Taxpayers or a related person; (iii) is under objection; (iv) is before the courts or, if a judgment has been issued, the time limit for appeal has not expired. ...

Aco files its tax returns with the XXXXXXXXXX Tax Services Office and its mailing address is XXXXXXXXXX; and Bco files its tax returns with the XXXXXXXXXX Tax Services Office and its mailing address is XXXXXXXXXX We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling request herein are: (i) dealt with in an earlier return of either Aco or Bco or a related person; (ii) being considered by a Tax Services Office or a Taxation Centre in connection with an income tax return previously filed by Aco, Bco or a related person; (iii) under objection by Aco, Bco or a related person; (iv) the subject of a previous ruling issued by the Income Tax Rulings Directorate to Aco, Bco or a related person; nor (v) before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

We understand that to the best of our knowledge and that of the taxpayer involved, none of the issues involved in this ruling request herein is: (a) dealt with in an earlier return of the taxpayer or a related person; (b) being considered by tax services office or a taxation centre in connection with any income tax return previously filed by the taxpayer or a related person; (c) under objection by the taxpayer 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 expired; or (e) the subject of a previous ruling issued by the Income Tax Rulings Directorate of the CRA. ...

We understand that, to the best of your knowledge and that of the taxpayer involved, none of the issues contained in this ruling request herein are: (i) dealt with in an earlier return of A Co or a related person; (ii) being considered by a tax services office or a taxation centre in connection with a tax return already filed by A Co or a related person; (iii) under objection by A Co or a related person; (iv) the subject of a previous ruling issued by the Income Tax Rulings Directorate to A Co or a related person; nor (v) before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

In connection with this use, the purpose test will be met if the borrowed money replaces capital (contributed capital or accumulated profits) that was being used for purposes that would have qualified for interest deductibility had the capital been borrowed money (eligible purposes). ...

Other Information To the best of your knowledge and that of Parentco, none of the issues involved in this advance income tax ruling is: in an earlier return of Parentco, or a related person; being considered or under assessment by a tax services office or taxation centre in connection with a previously filed tax return of Parentco or a related person; under objection by Parentco or a related person; before the courts, and no judgement has been issued which may be under appeal; or the subject of a ruling previously issued by the Directorate, other than as mentioned above. ...

We understand that, to the best of your knowledge and that of Partner 1, Partner 2 and Foreign Co, none of the issues involved in this ruling request: (i) is being considered by a tax services office or taxation centre in connection with a previously filed tax return of Partner 1, Partner 2, Foreign Co or a related person of any of them, (ii) is under objection by Partner 1, Partner 2, Foreign Co or a related person of any of them, or (iii) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...

For example, if a SOPARFI is created or used in connection with a treaty shopping arrangement where the SOPARFI is in fact only a "resident of convenience", we would not consider it to be a resident of Luxembourg for the purposes of the Treaty. ...

PlacerDome Canada Limited, 2006 SCC 20) have confirmed that whether an activity constitutes hedging depends on sufficient inter-connection or integration with the underlying transaction. ...

We understand that to the best of your knowledge, and that of the taxpayer involved, none of the matters considered in this ruling request are: (a) in an earlier return of the taxpayer or related persons; (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the taxpayer or related persons; (c) under objection by the taxpayer or related persons; (d) before the courts; or (e) the subject of a ruling previously issued by this Directorate to the taxpayer or related persons. ...