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We understand that to the best of your knowledge and that of the taxpayer involved, none of the issues described herein is: (i) dealt with in an earlier return of DC or a related person; (ii) being considered by a tax services office or a taxation centre in connection with a previously filed return of DC or a related person; (iii) under objection by DC 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 the Income Tax Rulings Directorate. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

To the best of your knowledge and that of the above-referenced taxpayer, none of the issues raised in the Rulings Request is: (i) in an earlier income tax return of the above-referenced taxpayer or a person related to that taxpayer; (ii) being considered by a tax services office or a taxation centre in connection with a previously filed tax return of the above-referenced taxpayer or a person related to that taxpayer; (iii) under objection by the above-referenced taxpayer or a person related to that taxpayer; (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. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

The Subco Debt includes the aggregate amount owing to Finco in respect of the Finco Bonds, an amount outstanding in connection with a XXXXXXXXXX issuance of bonds by Finco and other intercompany notes previously issued to Subco by Finco. ... To the best of your knowledge and that of Parent, none of the issues involved in this ruling letter: (i) is in an earlier return of Parent or any related persons of Parent, (ii) is being considered by a tax services office or taxation centre in connection with a previously filed tax return of Parent or any related persons of Parent, (iii) is under objection by Parent or any related persons of Parent, or (iv) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired. 16. ...

We understand that to the best of your knowledge, and that of the taxpayers involved, none of the matters considered in this ruling request is: a) in an earlier return of the taxpayers or related persons; b) being considered by a tax services office or taxation 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. ... In connection with the exchange: a. the DC Common Shares so exchanged will be cancelled; and b. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues contained herein is being considered by a Tax Services Office or a Taxation Centre in connection with any tax return already filed and none of the issues is under objection or appeal. ... “Computer Equipment” means certain of the computer equipment owned by the XXXXXXXXXX Partnership used in connection with the XXXXXXXXXX. ...

We understand that to the best of your knowledge and that of the taxpayers involved none of the issues involved in the requested rulings is being considered by a tax services office or a taxation centre in connection with a tax return already filed, or is under objection or appeal. ... This reorganization had not been carried out in connection with the Proposed Transactions described herein nor is it part of the same series of transactions as the Proposed Transactions. 24.On XXXXXXXXXX, XXXXXXXXXX, a wholly-owned subsidiary of XXXXXXXXXX, issued U.S. ...

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 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 the taxpayers or a related person; (iii) is under objection by the taxpayers or a related person; and (iv) is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ... In connection with the winding-up; i) DC1 will distribute to Holdco 1 the 1st Sub-Holdco 1 Note; ii) DC1 will distribute to Holdco 2 the 1st Sub-Holdco 2 Note and the 1st Holdco 2 Note; iii) DC1 will distribute to Newco 3 the 1st Sub-Newco 3 Note; iv) DC2 will distribute to Holdco 1 the 2nd Sub-Holdco 1 Note; v) DC2 will distribute to Holdco 2 the 2nd Sub-Holdco 2 Note and the 2nd Holdco 2 Note; vi) DC2 will distribute to Newco 3 the 2nd Sub-Newco 3 Note; vii) DC3 will distribute to Holdco 1 the 3rd Sub-Holdco 1 Note; viii) DC3 will distribute to Newco 1 the Sub-Newco 1 Note; and ix) DC3 will distribute to Newco 2 the Sub-Newco 2 Note. ...

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. ... In addition, there is no connection between the decision to redeem or cancel the XXXXXXXXXX Preferred Shares and the XXXXXXXXXX Preferred Shares and the issuance of XXXXXXXXXX Existing B Shares as described in Paragraph 6. 6. ...

However, the portion of these expenses that can reasonably have been incurred in connection with the corporation's business may be deductible or capitalized, depending on the case. When determining the value of the benefit for the purposes of subsection 15(1) of the Act, the portion of these expenses that can reasonably have been incurred in connection with the corporation's business must also be disregarded. ...

To the best of your knowledge, and that of the taxpayer involved, none of the issues involved in this ruling request is: (i) in a previously filed tax return of the taxpayer or a person related to the taxpayer; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or a person related to the taxpayer; (iii) under objection by the taxpayer or a person related to the taxpayer; (iv) the subject of a current or completed court process involving the taxpayer or a person related to the taxpayer; or (v) the subject of an advance income ruling previously issued by the Income Tax Rulings Directorate. ... In connection with the Canadian DC Share Exchange: (a) Canadian DC and Forco 1 will not make a joint election under the provisions of subsection 85(1); and (b) under the BCA 1, Canadian DC will add to the Stated Capital accounts of the Canadian DC New Common Shares and the Canadian DC Special Shares issued on the Canadian DC Share Exchange an aggregate amount equal to Stated Capital of the Canadian DC Common Shares immediately before the Canadian DC Share Exchange. ...