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You advise that to the best of your knowledge and that of the taxpayers referred to above, none of the issues involved in the ruling request: i. is in an earlier return of the taxpayers or a related person; ii. is being considered by a tax services office or tax centre in connection with a previously filed tax return of the taxpayers or a related person; iii. is under objection by the taxpayers 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; or v. is the subject of a ruling previously issued to the taxpayers, other than ruling XXXXXXXXXX, by the Directorate. ...

29 April 2008 External T.I. 2006-0215891E5 F- Partnership Interest & Departure Tax Unedited CRA Tags 85(1); 85(1.1); 220(4.5) Principal Issues: In a given situation, whether (1) a partnership interest could be considered an eligible property under subsection 85(1.1)? ...

You have advised that to the best of your knowledge, and that of the taxpayer, none of the issues involved in this Ruling is: (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 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 expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

You have advised that to the best of your knowledge, and that of the taxpayer, none of the issues involved in this Ruling is: (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 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 expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

Other Comments The application of the Offshore Articles of the relevant tax treaties and the general anti-avoidance rule ("GAAR") may be considered in the type of situation you describe. ...

We understand that to the best of your knowledge and that of the Applicants, none of the issues raised in the Ruling Request are: (a) identified in an earlier tax return of the Applicants or of a related person; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the Applicants or of a related person; (c) under objection by the Applicants or by a related person; (d) before the courts with respect to the Applicants or persons related to the Applicants or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (e) the subject of a ruling previously issued by the Income Tax Rulings and Interpretations Directorate of the Canada Revenue Agency, to the Applicants or persons related to the Applicants. ...

We understand that, to the best of your knowledge and that of the taxpayer involved, none of the issues contained in this ruling request herein are: (i) dealt with in an earlier return of Acquireco 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 Acquireco or a related person; (iii) under objection by Acquireco or a related person; (iv) the subject of a previous ruling issued by the Income Tax Rulings Directorate to Acquireco or a related person; nor (v) before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

Any dividend paid by the payer corporation is considered to be paid first out of the safe income on hand attributable to the recipient corporation's shares of the payer corporation. ...

We understand that to the best of your knowledge and that of the above-noted taxpayer, none of the issues involved in this advance income tax ruling are: (a) in an earlier return of the taxpayer or a related person; (b) 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; (c) under objection by the taxpayer or a related person; (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (e) the subject of a ruling previously issued by the 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 tax return of A Co or a related person; (ii) being considered by a 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 to A Co or a related person; nor (v) before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has expired. ...