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To the best of your knowledge and that of the taxpayers involved: (i)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, and (ii)none of the issues involved in the requested rulings is the subject of any notice of objection or is under appeal. ... In connection with the winding-up, DC will distribute to Holdco A and Holdco B, respectively, the Sub-Holdco A Note and the Sub-Holdco B Note. ...

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, Canco will distribute to Childco 1, Childco 2, Childco 3 and Childco 4, respectively, the Childco 1 Note, Childco 2 Note, Childco 3 Note and the Childco 4 Note. ...

We also acknowledge your letter of XXXXXXXXXX and our telephone conversations in connection herewith. 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 district tax services office or a taxation centre in connection with a tax return already filed, or is under objection or appeal. ...

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 taxation services office or a taxation centre in connection with a tax return already filed, or is under objection or appeal. ... Aco will agree to reimburse Bco for all expenses incurred by it in connection with the Proposed Transactions. ...

We also acknowledge your letters of XXXXXXXXXX and our telephone conversations in connection herewith. 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. ...

To the best of your knowledge, and that of the parties to this ruling, none of the issues contained in this advance income tax ruling: 1. is in an earlier return of the taxpayer or a related person; 2. is being considered by a tax services office or a taxation centre in connection with a previously filed tax return of the taxpayer or a related person, 3. is under objection by the taxpayer or related person, 4. is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired, or 5. is the subject of a ruling previously issued by the Directorate. ... In connection with the wind up, XXXXXXXXXX will distribute to the Sistercos and Brotherco, respectively, the Sisterco Notes and the Brotherco Note. ...

To the best of your knowledge, none of the issues involved in this advance ruling request is being considered by a Tax Services Office or a Taxation Centre in connection with a tax return already filed and none of the issues is under objection. ... Following the redemption of the Class A shares and Class B shares as described in paragraph 17 above, the shareholders of Amalco will, by special resolution, resolve to wind up and dissolve Amalco pursuant to XXXXXXXXXX In connection with the winding-up, Amalco will distribute Promissory Note A to XXXXXXXXXX and Promissory Note B to XXXXXXXXXX. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in this ruling is: a. in an earlier 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. before the courts, or e. the subject of a ruling previously issued by this Directorate. ... In connection with the Proposed Transactions, XCO is preparing a schedule that will maintain separate classes of depreciable property in respect of each business. 4. ...

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 related persons; (ii) being considered by a tax services office ("TSO") or taxation centre ("TC") in connection with a previously filed tax return of the taxpayers or related persons; (iii) under objection by the taxpayers or related persons; (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. ... The amount shall be designated pursuant to the resolution of the directors of each of the Transferees made in connection with the issuance of such share. ...

We understand that 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. ... However, if the offeror is a Non-Resident, the offeror will not be entitled to vote any of his Class 1 Units, nor to receive distributions of income or to have them counted in connection with a written resolution of Unitholders if he holds or acquires directly or indirectly 10% or more of the issued and outstanding Class 1 Units. ...