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You have advised that to the best of your knowledge, and that of all the taxpayers involved, none of the issues raised in this letter are being considered by any Tax Service Office ("TSO") and/or Taxation Centre in connection with any tax return already filed by the taxpayers, or any person related to the taxpayers, nor are any of these issues under objection, appeal, or 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 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 the taxpayers or a related person; (iii) under objection by the taxpayers 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 judgment has been issued, the time limit for appeal to a higher court has not expired. ...

For greater certainty, the proposed transactions described herein, in and by themselves, will not be considered to result in a disposition or increase in interest described in subparagraphs 55(3)(a)(i) to (v) with respect to the dividends deemed to be received by Realty. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is being considered by a tax services office or a taxation centre in connection with any tax return already filed and none of the issues is under objection or appeal. ...

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 tax return previously filed by any of the taxpayers or a related person; (iii) under objection by any of the taxpayers or a related person; (iv) before the courts and there is no judgment that has been issued in which the time limit for appeal to a higher court has not expired; and (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

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 tax 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 Directorate to the Corporation. ...

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 Agency 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 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. ...

Jurisprudence dealing with resulting trusts has considered situations where there was a gain on the disposition of property where the husband then alleged that he held one-half the property on a resulting trust for his wife. ...

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. ...