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To the best of your knowledge, and that of the taxpayer involved, none of the issues contained herein is: (i) dealt with 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; or (iv) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ...

To the best of your knowledge, none of the issues involved in this ruling are: i) in an earlier return of the Employer, a Member, or any person related to the Employer or a Member; ii) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Employer, a Member, or any person related to the Employer or a Member; iii) under objection by the Employer, a Member, or any person related to the Employer or a Member; iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; nor v) the subject of a ruling previously issued by the Directorate to the Employer. ...

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: (a) is in an earlier return of the taxpayer or a related person; (b) is 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; (c) is under objection by the taxpayer or a related person; (d) is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired; or (e) is the subject of a ruling previously issued by the Directorate. ...

To the best of your knowledge and that of the Company, none of the issues involved in this ruling request are: a) in an earlier return of the Company 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 Company or a related person, c) the subject matter of any notice of objection filed pursuant to the Act by the Company or a related person, d) before the courts, nor e) the subject of a ruling previously issued by this Directorate. ...

We understand that, to the best of your knowledge and that of the Corporation, none of the issues involved in the ruling request is: (i) in an earlier return of the Corporation 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 Corporation or a related person, (iii) under objection by the Corporation 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; nor (v) the subject of a ruling previously issued by the Directorate. ...

Robert Read, représentant alors Revenu Canada, à la conférence annuelle de 1988 de l'Association canadienne d'études fiscales: If it is reasonable to expect that any of the income earned or realized in a stub period will be offset by losses in the remainder of the year, then the calculation of the safe income on hand for the stub period should reflect the anticipated losses, since that income could not reasonably be considered to be reflected in the inherent gain in the shares. (1988 Conference Report, page 18:6) Selon vous, les commentaires de M. ...

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. ...

Reasons: In the particular situations, an arm's length purchaser should not be considered to be a "legal representative" as those terms are defined in subsection 248(1) of the Act. 2001-011260 XXXXXXXXXX S. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (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 one or any of the taxpayers or a related person; (iii) under objection by one or any of 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 any of the taxpayers, none of the issues involved in this ruling request is: (i) involved in an earlier return of any 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 (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...