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To the best of your knowledge and that of the taxpayers involved, none of the issues involved in this 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 judgment 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 taxpayer involved, none of the issues associated with this request: a) is involved in an earlier return of the taxpayer or a related person, b) is being considered by a tax services office or a taxation centre in connection with a tax return already filed by the taxpayer or a related person, c) is under objection, or d) is before the courts or, if a judgement has been issued, the time limit for appeal has not expired. 2. ...

On the second question, it is possible that the connection between the corresponding adjustment and the 247(12) deemed dividend might be sufficient to conclude favorably because they both emanate from the transfer pricing primary adjustments negotiated by both Competent Authorities. ...

We understand that, to the best of your knowledge and that of the Taxpayers involved, none of the proposed transactions or issues involved in this Ruling request are the same or substantially similar to transactions or issues that are: (i) in a previously filed tax return of the Taxpayers or a related person and: a. being considered by the CRA in connection with such return; b. under objection by the Taxpayers or a related person; or c. the subject of a current or completed court process involving the Taxpayers or a related person; or (ii) the subject of a Ruling request previously considered by the Income Tax Rulings Directorate. ...

We understand that, to the best of your knowledge and that of the Taxpayers involved, none of the proposed transactions or issues involved in this Ruling request are the same or substantially similar to transactions or issues that are: (i) in a previously filed tax return of the Taxpayers or a related person and: a) being considered by the CRA in connection with such return; b) under objection by the Taxpayers or a related person; c) the subject of a current or completed court process involving the Taxpayers or a related person; or (ii) the subject of a ruling request previously considered by the Income Tax Rulings Directorate. ...

We understand that to the best of your knowledge and that of the Taxpayers, none of the proposed transactions or issues involved in this Ruling are the same as or substantially similar to transactions or issues that are: (a) in a previously filed 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) the subject of a current or completed court process involving the Taxpayers or a related person; or (e) the subject of a ruling previously considered by the Income Tax Rulings Directorate in relation to the Taxpayers or a related person. ...

Manitoba Property Tax Credits Question 9 In connection with Manitoba property tax credits, there have been instances where clients have paid property taxes but have not received the homeowners assistance. ...

We understand that to the best of your knowledge and that of the Taxpayers, none of the proposed transactions and/or issues involved in this Ruling request are the same as or substantially similar to transactions or issues that are: (a) in a previously filed tax return of the Taxpayers or a related person and; (i) being considered by the CRA in connection with any such tax return; (ii) under objection by the Taxpayers or a related person; (iii) the subject of a current or completed court process involving the Taxpayers or a related person; or (b) the subject of a ruling request previously considered by the Income Tax Ruling Directorate in relation to the Taxpayers or a related person. ...

We understand that, to the best of your knowledge and that of the Taxpayers involved, none of the Proposed Transactions or issues involved in this Ruling request are the same or substantially similar to transactions or issues that are: (i) in a previously filed tax return of the Taxpayers or a related person and: a. being considered by the CRA in connection with such return; b. under objection by the Taxpayers or a related person; c. the subject of a current or completed court process involving the Taxpayers or a related person; or (ii) the subject of a ruling request previously considered by the Income Tax Rulings Directorate. ...

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. ...