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Accordingly, as noted in your letter, if the interest in the family asset which is being disposed of is not a capital property to the disposing spouse, or any of the spouses is not resident in Canada, the subsection 73(1) rollover cannot apply to the transfer, such that the disposition will generally be considered to have occurred at fair market value at the time of the triggering event. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues involved in this advance ruling request is being considered by a Tax Services Office or Taxation Centre in connection with a tax return already filed and none of these issues is under objection or appeal. ...

Additional Information To the best of your knowledge and the knowledge of the Company, none of the issues involved in this ruling request: a) is in an earlier return of the Company or of a person related to the Company; b) is being considered by a tax services office or tax centre in connection with a previously filed tax return of the Company or of a person related to the Company; c) is under objection by the Company or by a person related to the Company; d) is before the courts; or e) is the subject of a ruling previously issued by the Income Tax Rulings and Interpretations Directorate. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein: (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; or (v) is the subject of a ruling previously issued by the Directorate. ...

To the best of your knowledge and that of the Employer, none of the issues related to this request: (1) have previously been reported in the Employer's or any related party's prior income tax returns: (2) are being considered by a tax services office or taxation centre in connection with the Employer's or a related party's prior income tax return; (3) are under objection by the Participants or a related person; (4) are before the courts; and (5) are the subject of a ruling previously issued by this Directorate to the Employer but have been the subject of previous rulings issued by the Income Tax Rulings and Interpretations Directorate. ...

All the issued shares of the Corporation, both voting and non-voting, have to be considered, in determining whether the 90% ownership requirement was met. ...

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; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) 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, 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; (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 the knowledge of the Corporation, none of the issues involved in this request for an advance income tax ruling: (a) is in an earlier return of the Corporation or of a person related to the Corporation; (b) is being considered by a tax services office or taxation centre in connection with a previously filed return of the Corporation or of a person related to the Corporation; (c) is under objection by the Corporation or by a person related to the Corporation; (d) is before the courts; or (e) is the subject of a ruling previously issued by the Income Tax Rulings and Interpretations Directorate. ...

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 tax services office or a taxation centre in connection with a tax return already filed, or is under objection or appeal. ...