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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. ...

You have advised that to the best of your knowledge and that of all the taxpayers involved, none of the issues raised in this letter are being considered by any Tax Services Office and/or Taxation Centre in connection with any tax return already filed, nor are any of these issues under objection or appeal. ...

Subsection 141.1 (3) of the ETA provides that to the extent that a person does anything (other than make a supply) in connection with the acquisition of a commercial activity of the person, the person shall be deemed to have done that thing in the course of its commercial activities. ...

We understand that, to the best of your knowledge and that of the XXXXXXXXXX (collectively the "Subsidiaries"), none of the issues in the ruling request is: (a) in an earlier return of the Company, any of the Subsidiaries or a person related to the Company or any of the Subsidiaries, (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Company, any of the Subsidiaries, or a person related to the Company or any of the Subsidiaries, (c) under objection by the Company, any of the Subsidiaries, or a person related to the Company or any of the Subsidiaries, (d) before the courts, or (e) the subject of a ruling previously issued by the Directorate to the Company, any of the Subsidiaries or a person related to the Company or any of the Subsidiaries. ...

You are advised that, to the best of the knowledge of your clients, none of the issues described herein, as they apply specifically to such respective parties, is: (a) in an earlier return; (b) being considered by a tax services office or taxation centre in connection with any tax return previously filed; (c) the subject of any notice of objection or is under appeal; or (d) the subject of a previously issued ruling. ...

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. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling request are: (i) dealt with in an earlier return of the taxpayers or a related person, except for the issues, if any, relating to previous loss consolidation transactions described in Paragraphs 28 and 29; (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 Directorate; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...

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, the Group's and any Participants' knowledge, none of the issues involved in this ruling are: (i) in an earlier return of any member of the Group or a Participant, or any person related to any member of the Group or a Participant; (ii) being considered by a tax services office or tax centre in connection with a previously filed tax return of any member of the Group or a Participant, or any person related to any member of the Group or a Participant; (iii) under objection by any member of the Group or a Participant, or any person related to any member of the Group or a Participant; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; nor (v) the subject of a ruling previously issued by the Directorate to any member of the Group 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 any 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 any of the taxpayers or a related person; (iii) under objection by any 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. ...