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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 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 by the taxpayer or a Related Person; or (iv) is before the courts or, if a judgment has been issued, the time limit for appeal has not expired. ...

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 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. ...

To the best of your knowledge and that of the above-referenced taxpayers, none of the issues involved in this ruling is: (i) dealt with in an earlier return of any of the above-referenced 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 any of the above- referenced taxpayers or a related person, (iii) under objection or appeal by any of the above-referenced 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 taxpayers, none of the issues involved in the ruling request is: (i) in an earlier tax return of the taxpayers or a related person; (ii) being considered by a tax services office or a tax centre in connection with a tax return already filed by 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 issued by the Directorate to the taxpayers or a related person. ...

This is evident from the various dictionary definitions of the word "royalty" when used in connection with a sum payable. ...

This is evident from the various dictionary definitions of the word "royalty" when used in connection with a sum payable. ...

To the best of your knowledge and that of the above-referenced taxpayers, none of the issues involved in this ruling is: (a) dealt with in an earlier return of any of the above-referenced 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 above-referenced taxpayers or a related person, (c) under objection or appeal by any of the above-referenced taxpayers, 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 ruling previously issued by the Income Tax Rulings Directorate. ...

We understand that to the best of your knowledge and that of the taxpayers on whose behalf this ruling is being requested, none of the issues involved in this ruling request: (i) is in an earlier return of any such taxpayers 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 such taxpayers or a related person, (iii) is under objection by any of such taxpayers or a related person, (iv) is, in relation to any of such taxpayers or a related person, before the courts or is the subject of a judgment the time limit for appeal from which has not expired, or (v) is the subject of a ruling previously considered by the Directorate in relation to any of such taxpayers or a related person. ...

You have advised that to the best of your knowledge, and that of the responsible officers of the taxpayer, none of the issues involved in this ruling request is (a) in an earlier tax return of the taxpayer or any related person; (b) 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; (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 ruling previously issued by the Income Tax Rulings Directorate. ...

You have advised that to the best of your knowledge and that of each of the taxpayers on whose behalf this ruling is requested, none of the issues involved in this ruling is (a) in an earlier tax return of one of the taxpayers or any related person; (b) 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; (c) under objection by one of the taxpayers 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 not expired; or (e) the subject of a ruling previously issued by the Income Tax Rulings Directorate You have also advised that, to the best of your knowledge and that of each of the taxpayers, the proposed transactions will not result in any of the taxpayers or any related person described herein being unable to pay its existing outstanding tax liabilities. ...