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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: (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. ...

We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling request herein are: (i) dealt with in an earlier return of Parentco, NR Subco, Opco, Holdco, XXXXXXXXXX Co, or a related person; (ii) being considered by a tax services office or a taxation centre in connection with a tax return already filed by Parentco, NR Subco, Opco, Holdco, XXXXXXXXXX Co or a related person; (iii) under objection by Parentco, NR Subco, Opco, Holdco, XXXXXXXXXX Co or a related person; (iv) the subject of a previous ruling issued by the Income Tax Rulings Directorate to Parentco, NR Subco, Opco, Holdco, XXXXXXXXXX Co or a related person; nor (v) before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

., 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 XXXXXXXXXX. or a related person; (c) is under objection by XXXXXXXXXX. or a related person; or (d) is before the courts. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in this advance ruling is: (i) dealt with 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 not expired, or (v) the subject of a ruling previously issued by this 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 are: (i) in an earlier return of the taxpayers or any related person; (ii) being considered by a tax services office ("TSO") or taxation centre ("TC") in connection with a previously filed tax return by the taxpayers or any related person; (iii) under objection by the taxpayers or any 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 taxpayer involved, none of the issues involved in this 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 Center 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; or (iv) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...

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. ...

To the best of your knowledge and that of the Parent, the Corporation and the Employee, none of the issues involved in this ruling are: (a) in an earlier return of the Corporation or the Employee, or any person related to the Corporation, the Employee or a Participant; (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Corporation, the Employee or a Participant, or any person related to the Corporation, the Employee or a Participant; (c) under objection by the Corporation, the Employee, a Participant, or any person related to the Corporation, the Employee or a Participant; (d) before the courts; nor (e) the subject of an income tax ruling previously issued by CRA to the Corporation, the Employer or a Participant except as identified in 9 above. ...

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. ...

You have advised us that to the best of your knowledge, and that of the Taxpayers, none of the issues contained herein is: (a) in an earlier return of a Taxpayer or a person related to a Taxpayer; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of a Taxpayer or a person related to a Taxpayer; (c) under objection by a Taxpayer or a person related to a Taxpayer; (d) the subject of a ruling (other than the Existing Ruling) previously issued by the Income Tax Rulings Directorate; or (e) before the Courts. ...