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To the best of your knowledge and that of the above-referenced taxpayer, none of the issues involved in this ruling is: a) dealt with in an earlier tax return of the above-referenced taxpayer, 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 above-referenced taxpayer or a related person, c) under objection or appeal by the above-referenced taxpayer, 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, or e) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

You have advised that to the best of your knowledge, and that of the taxpayer involved, none of the issues contained herein is: a) in an earlier tax return of the taxpayer or a related person; b) being considered by a Tax Services Office or Taxation Centre in connection with any tax return previously filed by the taxpayer or a related person; c) under objection or appeal by the taxpayer 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; or e) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

Many of these trusts had no connection to Canada (foreign settlers, foreign trustees, foreign assets and foreign beneficiaries) absent concerns raised by the definition of "specified interest" in the current draft legislation. ...

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. ...

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. ...

To the best of your knowledge and that of the above-referenced taxpayers, none of the issues involved in this ruling is: (a) in an earlier return of the above-referenced 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 above-referenced taxpayers or a related person; (c) under objection by the above-referenced taxpayers or a related person; (d) before the courts; or (e) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

You have advised that, to the best of your knowledge, and that of the taxpayer involved, none of the issues involved in this ruling request is: (i) dealt with in an earlier return of B Co or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of B Co or a related person; (iii) under objection by B Co or a related person; (iv) before the courts; (v) the subject of a judgement previously issued by a Court of law; or (vi) 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 on whose behalf this ruling is being requested, none of the issues involved in this ruling request (i) is in an earlier return of any of such 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 any such taxpayers or a related person, (iii) is under objection by any of such taxpayers or a related person, (iv) is, in relation to any of such taxpayers or a related person, before the courts or is the subject of a judgment the time limit for appeal from which has not expired, or (v) is the subject of a ruling previously considered by the Directorate in relation to any of such taxpayers or a related person. ...

You have advised us that to the best of your knowledge and that of the Taxpayers, none of the issues involved in this ruling request are: (i) in an earlier return of the Taxpayers or persons who are related to the Taxpayers; (ii) being considered by a tax services office or taxation centre in connection with a tax return filed previously by any of the Taxpayers or persons who are related to any of the Taxpayers; (iii) under objection by any of the Taxpayers or any person who is related to the any of the Taxpayers; (iv) before the courts; 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 Group, none of the issues involved in this ruling: (a) relates to an earlier income tax return of The Group or a person related to The Group; (b) is being considered by a tax services office or taxation centre in connection with a previously filed tax return of The Group or a person related to The Group; (c) is under objection by The Group or a person related to The Group; (d) is before the courts; or (e) is the subject of a ruling previously considered by the Directorate. ...