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To the best of your knowledge, and that of the Taxpayers, none of the issues involved in this advance income tax ruling are: (i) in an earlier tax return of the Taxpayers or of a related person; (ii) being considered by a Tax Services Office or a Taxation Centre in connection with a previously-filed tax return of the Taxpayers or of a related person; (iii) under objection by the Taxpayers or by 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, other than the Initial Ruling, previously issued to the Taxpayers or a related person by the Income Tax Rulings Directorate. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling is: (a) in a previously filed income tax return of any of the taxpayers or a related person; (b) being considered by a Tax Services Office or a tax centre in connection with a previously filed income tax return of any of the taxpayers or a related person; (c) under objection by any of the taxpayers or a related person; (d) before the courts; or (e) the subject of a ruling previously issued by the Income Tax Rulings Directorate involving any of the taxpayers or a related person. ...

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 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, or (iv) before the courts. ...

You have advised that to the best of your knowledge, and that of the responsible officers of each of the taxpayers, 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. ...

To the best of your knowledge and that of each of the taxpayers, none of the issues involved in this ruling request is: in an earlier return of any of the taxpayers or a related person; being considered by a tax services office or taxation centre in connection with a previously filed tax return of any of the taxpayers or a related person; under objection by any of the taxpayers or a related person; before the courts; or the subject of a ruling previously issued by the Income Tax Rulings Directorate other than the advance income tax ruling issued on XXXXXXXXXX, 2006 (our reference 2006-020398) (the "Original Ruling") and the advance income tax ruling issued on XXXXXXXXXX, 2007 (our reference 2007-0232261R3)(the "Second Ruling"). ...

To the best of your knowledge, and that of the Taxpayers, none of the issues involved in this advance income tax ruling are: (i) in an earlier return of any of the Taxpayers or a related person; (ii) being considered by a Tax Services Office or a Taxation Centre 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 to any of the Taxpayers by the Income Tax Rulings Directorate. ...

We also acknowledge the additional information provided in your subsequent correspondence dated XXXXXXXXXX We understand that, to the best of your knowledge and that of the taxpayers, none of the issues involved in the ruling request is: a) in an earlier tax return of the taxpayers or of any related persons; b) being considered by a tax services office or a tax centre in connection with a tax return already filed by the taxpayers or by any related persons; c) under objection by the taxpayers or any related persons; d) before the courts or, e) the subject of a ruling previously issued by the Directorate to the taxpayers or to any related persons. ...

To the best of your knowledge, and that of the taxpayer involved, none of the issues involved in this 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 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 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; or (iv) before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...

We understand that to the best of your knowledge, and that of the taxpayers involved, none of the matters considered in this ruling request are: a) dealt with in an earlier return of the taxpayers 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 taxpayers or a related person; c) under objection by one or any 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 expired; and e) the subject of a ruling previously issued by this Directorate. ...