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To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in this ruling request is (i) in an earlier return of one 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 of the taxpayers or a related person; (iii) under objection by one 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 taxpayer involved, none of the issues contained herein is: (a) dealt with in an earlier return of the 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 taxpayer or a related person; (c) under objection by the taxpayer or a related person; (d) the subject of a ruling previously issued by the Income Tax Rulings Directorate; or (e) before the courts. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in this ruling request is (i) in an earlier return of one 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 of the taxpayers or a related person; (iii) under objection by one 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. ...

I understand that the United States, when faced with the same issue, made legislative amendments to codify restrictions on the deductibility of payments based on public policy grounds, such as punitive damages, bribes, fines and penalties, and expenditures in connection with the illegal sale of controlled substances. ...

You have been advised by your clients that to the best of their knowledge, none of the issues involved in this ruling, as they apply specifically to such parties: (i) is in an earlier return; (ii) is being considered by a tax services office or taxation centre in connection with a previously filed tax return; (iii) is under objection; (iv) is before the courts; or (v) is the subject of a previously issued ruling. ...

Except for the transactions that were the subject of an earlier advance income tax ruling dated XXXXXXXXXX, 2001 (#2001-011036- the "Prior Ruling") you have advised us that to the best of your knowledge and that of the taxpayer involved none of the issues involved in this ruling request: (a) is in an earlier return of the taxpayer or a related person; (b) is being considered by a tax services office ("TSO") or taxation centre ("TC") in connection with a previously filed tax return of the taxpayer or a related person; (c) is under objection by the taxpayer 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 issued by the Income Tax Rulings Directorate. ...

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. ...

We are examining it in connection with preparing the budgetary proposal implementation legislation. ...

You have advised that to the best of your knowledge and that of the taxpayers involved none of the issues involved in this ruling 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 judgement 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 taxpayers involved, none of the issues contained in this ruling request: i) is in an earlier income tax 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 income 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. ...