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To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein: (i) is in an earlier return of one of the 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 one of the taxpayers or a related person; (iii) is under objection by one of the taxpayers 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 not expired; or (v) is the subject of a ruling previously issued by the Directorate. ...

To the best of your knowledge, and that of any of the taxpayers, none of the issues involved in this ruling request is: (i) involved in an earlier return of any 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 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 (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

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: (a) is in an earlier return of the taxpayers or a related person; (b) is 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; (c) is under objection by the taxpayers or a related person; (d) is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired; or (e) is the subject of a ruling previously considered by the Directorate. ...

You have been advised by your clients that none of the issues contained herein is: (i) in an earlier return of the taxpayer or related persons; (ii) being considered by a Tax Services Office or Taxation Centre in connection with a previously filed return of the taxpayer or related persons; (iii) under objection by the taxpayer or related persons; (iv) before the courts; or (v) the subject of a ruling previously issued by the Directorate. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues involved in this ruling (a) is in an earlier return of the taxpayer(s) or a related person, (b) is being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer(s) or a related person, (c) is under objection by the taxpayer(s) or a related person, (d) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired, and (e) is the subject of a ruling previously issued by Revenue Canada or the CCRA. ...

Commissioner of Internal Revenue, which you provided to us, in connection with the current case. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (i) dealt with 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 one or any of the taxpayers or a related person; (iii) under objection by one or any of the taxpayers or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings Directorate; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...

To the best of your knowledge and that of any of the Taxpayers, none of the issues involved in this ruling request is: (i) involved in an earlier return of any 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 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 (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

It would be sufficient in this case to say that there is nothing in the transaction which necessarily implies that the testatrix (intending only a benefit to take effect after here death, and in connection with her will) meant to place this disposition of her property out of her control in her lifetime. ...

Principal Issues: standard ruling, no issues Position: Reasons: XXXXXXXXXX XXXXXXXXXX 3-992399 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 1999 Dear Sirs: Re: Advance income tax ruling XXXXXXXXXX We are writing in response to your letters of XXXXXXXXXX wherein you requested an advance income tax ruling in respect of the following taxpayers: (a) XXXXXXXXXX ("DC"), business number XXXXXXXXXX; (b) XXXXXXXXXX ("Aco"), business number XXXXXXXXXX; (c) XXXXXXXXXX ("Bco"), business number XXXXXXXXXX; (d) XXXXXXXXXX ("Cco"), business number XXXXXXXXXX; (e) XXXXXXXXXX ("A"), social insurance number XXXXXXXXXX; (f) XXXXXXXXXX ("B"), social insurance number XXXXXXXXXX; and (g) XXXXXXXXXX ("C"), social insurance numberXXXXXXXXXX; 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 taxpayers 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 taxpayers or a related person; 3. is under objection by the taxpayers 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. ...