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

In such circumstances, the application of subsection 245(2) would also have to be considered. ...

The interpretation refers to the "separate transactions" theory whereby the foreign currency component of a foreign currency borrowing is considered as a transaction separate from the borrowing itself. ...

The interpretation refers to the "separate transactions" theory whereby the foreign currency component of a foreign currency borrowing is considered as a transaction separate from the borrowing itself. ...

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. ...

We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in this ruling: (i) is in an earlier return of the taxpayer or a related person; (ii) 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; (ii) is under objection by the taxpayer or a related person; (iv) is before the courts; or (v) is the subject of a ruling previously issued by the Income Tax Rulings Directorate to the taxpayer or a related person. ...

The interpretation refers to the "separate transactions" theory whereby the foreign currency component of a foreign currency borrowing is considered as a transaction separate from the borrowing itself. ...

The interpretation refers to the "separate transactions" theory whereby the foreign currency component of a foreign currency borrowing is considered as a transaction separate from the borrowing itself. ...

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. ...

We understand that to the best of your knowledge and that of the taxpayers involved, none of the issues discussed in this ruling request is: (a) in an earlier return of the taxpayers or a related person; (b) being considered by a Tax Services Office or a Taxation Centre in connection with a previously filed tax return of any of the taxpayers or a related person; (c) under objection by any of the taxpayers or a related person; (d) subject to a ruling previously issued by the Income Tax Rulings Directorate to the taxpayers or a related person; or (e) before the courts. ...