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You have described a situation where a "principal-business corporation" (as defined in subsection 66(15) of the Act) has raised money through the issue of "flow-through shares" (also as defined in subsection 66(15) of the Act) and has used this money to do wind power development work, including site selection, wind feasibility, hydro connection feasibility, environmental feasibility, geotechnical study and process engineering relating to several proposed wind farm projects. ... In addition, amounts that would otherwise be included in the capital cost of depreciable property, other than costs incurred: A) for a temporary access road to the project, B) for clearing land as required to complete the project, C) for process engineering for the project, or D) for a test wind turbine, or any amount that would otherwise be included in the capital cost of intangible property, other than costs incurred: E) for making a service connection to transmit electricity to a purchaser, F) for a right of access to the project site during the start-up phase, or G) as described in A) to C) above, will not generally qualify as CRCE. ...

We also acknowledge the information provided in subsequent correspondence and during various telephone conversations in connection with your request (XXXXXXXXXX). We understand that to the best of your knowledge and that of the taxpayers involved none of the issues involved in the requested ruling: (i) is in an earlier return of a taxpayer identified in this document or a related person, (ii) is being considered by any Tax Services Office or Taxation Centre of the Agency in connection with a tax return already filed, (iii) is under objection by a taxpayer identified in this document or a related person, or (iv) is the subject of a ruling previously considered by the Directorate. ...

The New Partnership will assume any indebtedness assumed by Partner B and the Trust in connection with the dissolution of the Existing Partnership and the purchase by the Trust of Partner A's interest in the Special Assets. ... To the best of your knowledge and the knowledge of the Corporation, none of the issues involved in this request for an advance income tax ruling: (a) is in an earlier return of the Corporation or a person related to the Corporation; (b) is being considered by a tax services office or tax centre in connection with a previously-filed return of the Corporation or of a person related to the Corporation; (c) is under objection by the Corporation or by a person related to the Corporation; (d) is before the courts; or (e) is the subject of a ruling previously issued by the Income Tax Rulings Directorate to the Corporation or to a person related to the Corporation. ...

We also acknowledge the information provided in subsequent correspondence and during our various telephone conversations in connection with your request (XXXXXXXXXX). We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in the ruling request (i) is in an earlier return of the taxpayer or a related person, (ii) is being considered by a tax services office or taxation center in connection with a previously filed tax return of the taxpayer or a related person, (iii) is under objection by the taxpayer or 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 not expired, and (v) is the subject of a ruling previously issued by the Directorate. ...

DEFINITIONS a) "Act" means the Income Tax Act, R.S.C. 1985 (5th Supp.) c.1. as amended to the date hereof. b) "CCRA" means the Canada Customs and Revenue Agency. c) "Code" means the United States Internal Revenue Code of 1986, as amended to the date hereof. d) "Custodian" means the trustees of the 401(k) Plan. e) "Employee" means a Canadian resident employee of the Employer, on whose behalf contributions have been made to the 401(k) Plan for services rendered to the Employer that were primarily services rendered in Canada, or services rendered in connection with a business carried on by the Employer in Canada (or a combination of such services). ... To the best of your knowledge and that of the Employer, none of the issues involved in this request for an advance income tax ruling is: a. in an earlier return of the Employer or a related person, b. being considered by any tax services office or tax centre in connection with a previously filed tax return of the Employer or a related person, c. the subject matter of any notice of objection filed pursuant to the Act by the Employer or a related person, d. before the courts, or e. the subject of a ruling previously issued by this Directorate. ...

We also acknowledge the information provided in subsequent correspondence and during various telephone conversations in connection with your request XXXXXXXXXX. We understand that to the best of your knowledge and that of the taxpayers involved none of the issues involved in the requested ruling is: (i) in an earlier return of a taxpayer identified in this document or of a related person, (ii) being considered by any Tax Services Office or Taxation Centre of the CCRA in connection with a tax return already filed, (iii) under objection by a taxpayer identified in this document or by a related person. ...

We also acknowledge the information provided in subsequent correspondence and during our various telephone conversations in connection with your request (XXXXXXXXXX). We understand that, to the best of your knowledge and that of the taxpayers referred to above, none of the issues involved in the ruling request is: (i) 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) 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 Directorate. ...

We also acknowledge the information provided in your subsequent correspondence and during our various telephone conversations in connection with your request (XXXXXXXXXX). We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in the ruling request (i) is in an earlier return of the taxpayer or a related person, (ii) is being considered by a tax services office or taxation center in connection with a previously filed tax return of the taxpayer or a related person, (iii) is under objection by the taxpayer or 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 not expired, and (v) is the subject of a ruling previously issued by the Directorate. ...

Additional Information To the best of your knowledge and the knowledge ACO or CCO, none of the issues involved in this request for an advance income tax ruling: (a) is in an earlier return of ACO or CCO or of a person related to them; (b) is being considered by a tax services office or tax center in connection with a previously-filed return of ACO or of a person related to ACO; (c) is under objection by ACO or CCO or by a person related to them; or (d) is before the courts. ... Provided all expenses described in paragraph 13 above are paid as reimbursements for specific expenses incurred for the performance of services that were for the benefit of ACO in connection with financing granted to ACO, such fees, to the extent reasonable in the circumstances, will be exempt from tax under Part XIII by virtue of paragraph 212(4)(b). ...

We also acknowledge the information provided in subsequent correspondence and during our various telephone conversations in connection with your request (XXXXXXXXXX). We understand that, to the best of your knowledge and that of the taxpayer referred to above, none of the issues involved in the ruling request is: (i) in an earlier return of the taxpayer 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 taxpayer or a related person; (iii) under objection by the taxpayer 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 Directorate. ...