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To the best of your knowledge and that of the taxpayers involved, 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. ...

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 is: (i) in an earlier return 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 the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (iv) the subject to a ruling previously issued by the Income Tax Rulings Directorate. ...

This is evident from the various dictionary definitions of the word "royalty" when used in connection with a sum payable. ...

It would be sufficient in this case to say that there is nothing in the transaction which necessarily implies that the testatrix (intending only a benefit to take effect after here death, and in connection with her will) meant to place this disposition of her property out of her control in her lifetime. ...

You have been advised that, to the best of the knowledge of the above-mentioned taxpayers, none of the issues involved in this ruling is: (i) being considered by a tax services office or a taxation centre in connection with a tax return already filed; (ii) under objection; (iii) before the courts; or (iv) the subject of a previously issued ruling. ...

To the best of your knowledge, and that of B Co and A Co, none of the issues involved in this ruling contained herein is: (i) is in an earlier return of B Co or A Co or of a person related to either B Co or A Co; (ii) is being considered by a tax services office or taxation centre in connection with a previously filed tax return of either B Co or A Co or of a related person; (iii) is under objection by B Co or by A Co or by a related person; (iv) is before the courts; or if a judgment has been issued, the time limit for appeal to a higher court has expired; or (v) is the subject of a previously issued ruling. ...

To the best of your knowledge, and that of the First Nation, none of the issues involved in the ruling request is: (a) in an earlier return of the First Nation or a related person, (b) being considered by a tax services office or taxation center in connection with a previously filed tax return of the First Nation or a related person, c) under objection by the First Nation 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 considered by the Directorate in respect of the First Nation or a related person. ...

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: i) in an earlier return of the Corporation or the Employee, or any person related to the Corporation, the Employee or a Participant; ii) 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; iii) under objection by the Corporation, the Employee, a Participant, or any person related to the Corporation, the Employee or a Participant; iv) before the courts; nor v) the subject of an income tax ruling previously issued by CCRA to the Corporation, the Employer or a Participant. ...

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 taxpayer 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 the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; or (iv) 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 the taxpayer 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 the taxpayers or a related person; (iii) under objection by 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 not expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...