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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 the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or v) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ...

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 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 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; or (v) is the subject of a ruling previously issued by the Directorate. ...

To the best of your knowledge none of the issues involved in this ruling request is being considered by a tax services office or taxation centre in connection with a tax return already filed or is under objection or appeal or the subject of any ruling, other than the First Ruling, previously issued by the Directorate with respect to the Debtor or Trustco. ...

To the best of your knowledge, and that of the taxpayers involved, none of the matters considered in this ruling request are: (a) in an earlier return of the taxpayers or related persons; (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the taxpayers or related persons; (c) under objection by the taxpayers or related persons; (d) before the courts; or (e) the subject of a ruling previously issued by this Directorate to the taxpayers or related persons. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues involved in this request: (a) is involved 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 tax return already filed by the taxpayers or a related person, (c) is under objection, (d) is before the courts or, if a judgment has been issued, the time limit for appeal has not expired, and (e) is the subject of a ruling previously issued by the Income Tax Rulings and Interpretations Directorate. ...

To the best of your knowledge and that of the taxpayer involved, none of the issues associated with this request: a) is involved in an earlier return of the taxpayer or a related person, b) 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, c) is under objection, or d) is before the courts or, if a judgement has been issued, the time limit for appeal has not expired. 2. ...

On the second question, it is possible that the connection between the corresponding adjustment and the 247(12) deemed dividend might be sufficient to conclude favorably because they both emanate from the transfer pricing primary adjustments negotiated by both Competent Authorities. ...

We understand that, to the best of your knowledge and that of the Taxpayers involved, none of the proposed transactions or issues involved in this Ruling request are the same or substantially similar to transactions or issues that are: (i) in a previously filed tax return of the Taxpayers or a related person and: a. being considered by the CRA in connection with such return; b. under objection by the Taxpayers or a related person; or c. the subject of a current or completed court process involving the Taxpayers or a related person; or (ii) the subject of a Ruling request previously considered by the Income Tax Rulings Directorate. ...

We understand that, to the best of your knowledge and that of the Taxpayers involved, none of the proposed transactions or issues involved in this Ruling request are the same or substantially similar to transactions or issues that are: (i) in a previously filed tax return of the Taxpayers or a related person and: a) being considered by the CRA in connection with such return; b) under objection by the Taxpayers or a related person; c) the subject of a current or completed court process involving the Taxpayers or a related person; or (ii) the subject of a ruling request previously considered by the Income Tax Rulings Directorate. ...

We understand that to the best of your knowledge and that of the Taxpayers, none of the proposed transactions or issues involved in this Ruling are the same as or substantially similar to transactions or issues that are: (a) in a previously filed return of the 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 the Taxpayers or a related person; (c) under objection by the Taxpayers or a related person; (d) the subject of a current or completed court process involving the Taxpayers or a related person; or (e) the subject of a ruling previously considered by the Income Tax Rulings Directorate in relation to the Taxpayers or a related person. ...