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To the best of your knowledge and that of the taxpayer, none of the issues involved in this ruling contained herein is: (i) dealt with in an earlier return of A Co or a related person; (ii) being considered by any tax services office or taxation centre in connection with a previously filed tax return of A Co or a related person; (iii) under objection by A Co or a related person; (iv) the subject of a ruling previously issued by the Income Tax Rulings Directorate of the CRA to A Co or a related party; nor (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

To the best of the Company's and your knowledge, none of the issues involved in this Ruling are: (i) in an earlier tax return of the Company, a Participant or any person related to the Company or a Participant; (ii) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Company, a Participant or any person related to the Company or a Participant; (iii) under objection by the Company, a Participant or any person related to the Company 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 the Company, a Participant or any person related to the Company or a Participant. ...

Accordingly, when a debt is forgiven, it is generally considered a disposition to the creditor. ...

To the best of your knowledge and that of the taxpayer, none of the issues involved in this ruling contained herein is: (i) dealt with in a return of Finco or a related person; (ii) being considered by any tax services office or taxation centre in ` connection with a previously filed tax return of Finco or a related person; (iii) under objection by Finco or a related person; (iv) the subject of a ruling previously issued by the Income Tax Rulings Directorate of the CRA to Finco or a related party; nor (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

We understand that to the best of your knowledge and that of the taxpayers involved, none of the issues involved in this ruling request herein is: (i) in a return of the taxpayer or related persons; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or related persons; (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 expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings and Interpretation Directorate of the CRA. ...

2 December 2011 External T.I. 2011-0424446E5- Interaction of Subsections 249(3.1) and 249(4) Unedited CRA Tags 125(1); 125(7); 256(9); 249(4); 251(5)(b); 249(3.1) Principal Issues: Whether, in the circumstances where a sale of the shares of the capital stock of a Canadian-controlled private corporation ("CCPC") to a non-resident purchaser results in a change of CCPC status and a change of control on the same day, the hypothetical corporation would be considered to be a CCPC throughout the taxation year such that the small business deduction provisions of subsection 125(1) would apply? ...

To the best of your knowledge and that of the aforementioned taxpayers, none of the issues involved in this request for an advance income tax ruling is: (i) in an earlier return of a taxpayer or persons related to a taxpayer; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of a taxpayer or persons related to a taxpayer; (iii) under objection by a taxpayer or persons related to a taxpayer; (iv) before the courts; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

You have advised us that to the best of your knowledge and that of the taxpayers involved, none of the issues involved in this rulings are: (i) dealt with 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 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 an appeal to a higher court has not expired; or (v) the subject of a ruling previously issued 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 contained herein are: (i) dealt with in an earlier return of Parent, Lossco or a related person; (ii) being considered by a tax services office or a taxation centre in connection with a tax return already filed by Parent, Lossco or a related person; (iii) under objection by Parent, Lossco or a related person; (iv) the subject of a previous ruling issued by the Income Tax Rulings Directorate to Parent, Lossco or a related person; or (v) before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

To the best of your knowledge and that of the above-referenced taxpayer, none of the issues raised in the Rulings Request is: (i) in an earlier income tax return of the above-referenced taxpayer or a person related to that taxpayer; (ii) being considered by a tax services office or a taxation centre in connection with a previously filed tax return of the above-referenced taxpayer or a person related to that taxpayer; (iii) under objection by the above-referenced taxpayer or a person related to that taxpayer; (iv) before the courts or, if a judgement 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. ...