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We understand that, to the best of your knowledge, none of the issues involved in the ruling request: (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, (iii) is under objection by the taxpayer 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, and (v) is the subject of a ruling previously issued by the Directorate. ...

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 ("TSO") or taxation centre ("TC") 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 Income Tax Rulings Directorate. ...

To the best of your knowledge, and that of A Co, none of the issues involved in this ruling as they apply specifically to A Co and its subsidiaries herein: (i) is in an earlier return of A Co or a related person related to A Co; (ii) is 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) is under objection by A Co 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 previously issued ruling. ...

The Tax Court of Canada's reasoning in the RMM Canadian Enterprises Inc. case, referred to above, may support the view that A would not be considered to deal at arm's length with Opco with respect to the acquisition by Opco of the Aco common shares. ...

To the best of your knowledge, and that of the taxpayers, none of the issues involved in this ruling is: (i) in an earlier return of the taxpayers or a related person; (ii) being considered by a Tax Services Office or a Taxation Centre in connection with any 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 judgement has been issued, the time limit for appeal to a higher court has not expired; or (v) the subject of a previously issued ruling. ...

Finally, the potential application of subsections 55(2) and 245(2) should be considered in any particular situation. 2002-017909 XXXXXXXXXX S. ...

To the best of your knowledge and that of the Company, none of the issues contained herein: (i) is in an earlier tax return of the Company 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 Company or a related person; (iii) is under objection by the Company or a related person; (iv) is before the Courts or, if a judgement has been issued, the time limit for appeal to a higher Court has expired; or (v) is the subject of an advance income tax ruling previously issued by the Income Tax Rulings Directorate to the Company or a related person. ...

We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in the requested rulings is being considered by a taxation services office or a taxation centre in connection with a tax return already filed, or is under objection or appeal. ...

We understand that to the best of your knowledge and that of the taxpayers involved: i) none of the issues involved in the requested ruling is being considered by any District Tax Services Office or Taxation Centre of the Department in connection with a tax return already filed, and ii) none of the issues involved in the requested ruling is the subject of any notice of objection or is under appeal. ...

To the best of your knowledge, none of the issues involved in this ruling: i) are in an earlier return of the Employer or a person related to the Employer; ii) are being considered by a tax services office or tax centre in connection with a previously filed tax return of the Employer or a person related to the Employer; iii) are under objection by the Employer or a person related to the Employer; iv) are before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired, and v) are the subject of a ruling previously issued by the Directorate. ...