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We understand that, to the best of your knowledge and that of the taxpayers, none of the issues involved in the Ruling request: (i) is in an earlier return of the Corporation, the Employer or a related person, (ii) is being considered by a Tax Services Office or a Taxation Center in connection with a previously filed return of the Corporation, the Employer or a related person, (iii) is under objection by the Corporation, the Employer or a related person, (iv) is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has expired, or (v) is the subject of a Ruling previously issued by the Directorate to the Corporation, the Employer or a related person. 29. ...

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 related persons; (ii) being considered by a tax services office ("TSO") or taxation centre ("TC") in connection with a previously filed tax return of the taxpayers or related persons; (iii) under objection by the taxpayers or related persons; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

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

We understand that, to the best of your knowledge, none of the issues involved in the ruling request: (i) is in an earlier return of the taxpayer 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 taxpayer or a related person, (iii) is under objection or appeal by the taxpayer 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 Canada Revenue Agency. ...

We understand that, to the best of your knowledge and that of both Corporation A and Corporation B, none of the issues involved in this ruling request is: (a) in an earlier return of Corporation A or Corporation B or a related person; (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of Corporation A or Corporation B or a related person; (c) under objection by Corporation A or Corporation B or a related person; (d) before the courts; nor (e) the subject of a ruling previously issued to Corporation A or Corporation B or a related person by the Income Tax Rulings Directorate. ...

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

To the best of your knowledge, the Corporation's knowledge and any Participants' knowledge, none of the issues involved in this ruling are: (i) in an earlier return of the Corporation or a Participant, or any person related to the Corporation or a Participant; (ii) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Corporation or a Participant, or any person related to the Corporation or a Participant; (iii) under objection by the Corporation or a Participant, or any person related to the Corporation or a Participant; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; nor (v) the subject of a ruling previously issued by the Directorate to the Corporation or a Participant. ...

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 any 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. ...

Our comments As you know, XXXXXXXXXX made reference to an earlier opinion (Document E2000-004916) we issued in connection with another non-resident insurer. ...

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 this Directorate. ...