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To the best of your knowledge and that of the Canadian General Partner and the Canadian Limited Partner, none of the proposed transactions involved in this ruling letter: (i) is in an earlier return of the Canadian General Partner or the Canadian Limited Partner or any person related to the Canadian General Partner or the Canadian Limited Partner, (ii) is being considered by a tax services office or taxation centre in connection with a previously filed tax return of the Canadian General Partner or the Canadian Limited Partner or any person related to the Canadian General Partner or the Canadian Limited Partner, (iii) is under objection by the Canadian General Partner or the Canadian Limited Partner or any person related to the Canadian General Partner or the Canadian Limited Partner, (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 any advance income tax ruling previously issued to the Canadian General Partner or the Canadian Limited Partner or any person related to the Canadian General Partner or the Canadian Limited Partner. ...

We understand that, to the best of your knowledge and that of the taxpayers, none of the issues involved in the ruling is: (i) 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 the taxpayers or a related person, (iii) under objection by the taxpayers or a related person, (iv) before the courts, or (v) the subject of a ruling previously considered by the Directorate involving the taxpayers or a related person. ...

You have advised that to the best of your knowledge, and that of the above-referenced taxpayers involved, none of the issues contained herein is: (i) dealt with in an earlier tax return of the taxpayers or a related person; (ii) being considered by a tax services office or taxation centre in connection with any 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 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. ...

We understand that, to the best of your knowledge and that of the taxpayer, none of the issues involved in the ruling request is: (i) in an earlier return of the taxpayer or a related person; (ii) 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) under objection by 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 not yet expired; (v) the subject of a ruling previously considered by this Directorate to the taxpayer or a related person. ...

In general, the POD of goodwill in connection with a business may be considered as an eligible capital ("EC") amount under subsection 14(1) and may apply to reduce the "cumulative eligible capital" ("CEC") pool pursuant to element E of the CEC definition in subsection 14(5) of the Act. ...

To the best of your knowledge and that of the above-referenced taxpayer, none of the issues involved in this ruling is: a) dealt with in an earlier tax return of the above-referenced taxpayer, 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 above-referenced taxpayer or a related person, c) under objection or appeal by the above-referenced taxpayer, or a related person, or d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

As such any payments in respect of the copyright of a literary, dramatic, musical or artistic work, including the right in respect of the translation, performance, telecommunication or broadcast of one of the aforementioned works will not be subject to withholding tax unless that payment is for a right in or the use of a motion picture film or a film or video tape for use in connection with television that is to be used or reproduced in Canada. ...

We understand that, to the best of your knowledge and that of the above-referenced Company, none of the issues involved in the ruling request is: (i) in an earlier return of the Company or a related person; (ii) 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) under objection by the Company or a related person; (iv) before the courts; nor, (v) the subject of an advance income tax ruling previously issued by the Directorate. ...

We understand that, to the best of your knowledge and that of the taxpayers named above, none of the issues involved in the ruling request is: (i) involved in an earlier return of the taxpayer or a related person; (ii) 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) under objection by the taxpayer or a related person; (iv) before the courts; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate involving the taxpayer or a related person. ...

We understand that, to the best of your knowledge and that of the taxpayer, none of the issues involved in the ruling request are: (i) in an earlier return of the taxpayer or a related person, (ii) 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) under objection by the taxpayer or a related person, (iv) before the courts, or (v) the subject of a ruling previously considered or issued by the Directorate to the taxpayer or a related person. ...