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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 involved, none of the issues involved in this ruling is: (i) involved 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 expired, or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate (other than Ruling no. 2006-018243 []). ... In general, an acquisition of shares of the capital stock of Parent or Xco by former shareholders of Target, each of which would not be a person described in clause 88(1)(c)(vi)(B) if this clause were read without reference to subclause 88(1)(c)(vi)(B)(II), will not necessarily be considered to occur as part of a series of transactions or events that includes the amalgamation of Target with Newco. b. ...

The tax account numbers, Tax Services Offices, and Tax Centres of the taxpayers involved are as follows: XXXXXXXXXX (collectively, the “Taxpayers”) 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 tax return of the Taxpayers or a related person and: i. being considered by the CRA in connection with such return; ii. under objection by the Taxpayers or a related person; or 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 Rulings Directorate. ...

PRELIMINARY MATTERS To the best of your knowledge, and that of the responsible officers of the above-noted taxpayer, none of the proposed transactions 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 above-noted taxpayer or a related person and: i. being considered by the CRA in connection with such return; ii. under objection by the above-noted taxpayer or a related person; or iii. the subject of a current or completed court process involving the above-noted taxpayer or a related person; or (b) the subject of a ruling request previously considered by the Income Tax Rulings Directorate in relation to the taxpayer or a related person. ...

We understand that, to the best of your knowledge and that of the taxpayer, except to the extent described herein, none of the transactions and/or issues in this letter are the same as or substantially similar to transactions and/or issues that are: (i) in a previously filed tax return of the taxpayer or a related person; (ii) being considered by a tax services office or tax 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) the subject of a current or completed court process involving the taxpayer or a related person; or (v) the subject of a ruling request previously considered by the Directorate. ...

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 as 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, none of the Proposed Transactions and/or issues involved in this ruling request are the same as, or substantially similar to, transactions and/or issues that are: a. in a previously filed return of the Taxpayers or a related person and; i. being considered by the Canada Revenue Agency in connection with such return; ii. under objection by the Taxpayers or a related person; or 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 Rulings Directorate. ...

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

The consistency principle, simply stated, refers to the requirement to use the same accounting principles from one period to another. 3 A change in an accounting principle to a more preferred method results in inconsistency, however, such a change is acceptable provided the effect of the change is disclosed and, where applicable, prior period adjustments are made. 3 The application of the consistency principle in valuing inventory for tax purposes was considered in The Queen v. ...

You have advised us that to the best of your knowledge and that of the taxpayer involved none of the issues involved in this ruling request are: (i) in an earlier return of the taxpayer or any related person; (ii) being considered by a tax services office ("TSO") or taxation centre ("TC") in connection with a previously filed tax return by the taxpayer or any related person; (iii) under objection by the taxpayer or any 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. ...