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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. ...

To the best of your knowledge and the knowledge of XXXXXXXXXX, none of the issues involved in this ruling request is being considered by a tax services office or a taxation centre in connection with an income tax return already filed, and none of the issues is under objection or appeal. ...

We understand that to the best of your knowledge and that of XXXXXXXXXX, none of the issues contained herein: (a) is in an earlier return of XXXXXXXXXX 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 XXXXXXXXXX or a related person; (c) is under objection by XXXXXXXXXX or a related person; (d) is before the courts or, if a judgment 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 and Interpretations Directorate of Revenue Canada, DEFINITIONS In this letter unless otherwise expressly stated: (a) "Act" means the Income Tax Act, R.S.C. 1985 (5th Supp.) c.1, as amended to the date hereof, and unless otherwise stated, every reference herein to a part, section, subsection, paragraph or subparagraph is a reference to the relevant provision of the Act; (b) "ACB" means "adjusted cost base" and has the meaning assigned by section 54; (c) "capital property" has the meaning assigned by section 54; (d) "fiscal period" has the meaning assigned by subsection 249.1(1); (e) XXXXXXXXXX; (f) "paid-up capital" has the meaning assigned by subsection 89(1); (g) "proceeds of disposition" has the meaning assigned by section 54; (h) "public corporation" has the meaning assigned by subsection 89(1); (i) "short-term preferred share" has the meaning assigned by subsection 248(1); (j) "taxable Canadian corporation" has the meaning assigned by subsection 89(1); (k) "taxable dividend" has the meaning assigned by subsection 89(1); and (l) "taxable preferred share" has the meaning assigned by subsection 248(1). ...

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

You have confirmed that to the best of your knowledge and that of XXXXXXXXXX none of the issues contained herein: (a) is in an earlier return of XXXXXXXXXX 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 XXXXXXXXXX or a related person; (c) is under objection by XXXXXXXXXX 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 and Interpretations Directorate of Revenue Canada. ...

Pursuant to subparagraph 212(1)(c)(ii), Part XIII withholding tax applies to an amount that can reasonably be considered to be a distribution to a non-resident of a capital dividend received by a trust from a corporation resident in Canada. ...

We understand that to the best of your knowledge and that of the above-noted taxpayer, none of the issues involved in this advance income tax ruling are: (a) in an earlier return of the taxpayer or a related person; (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the taxpayer or a related person; (c) under objection by the taxpayer or a related person; (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (e) the subject of a ruling previously issued by the Directorate. ...

We understand that, to the best of your knowledge and that of the taxpayer involved, none of the issues involved in the Ruling request is: (a) in an earlier return of the taxpayer or a related person; (b) being considered by a Tax Services Office or Taxation Center in connection with a previously filed tax return of the taxpayer or a related person; (c) under objection by the taxpayer or a related person; (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (e) the subject of a Ruling previously issued by the Directorate. ...

We understand that, to the best of your knowledge and that of the taxpayer involved, none of the issues involved in the Ruling request is: (a) in an earlier return of the taxpayer or a related person; (b) being considered by a Tax Services Office or Taxation Center in connection with a previously filed tax return of the taxpayer or a related person; (c) under objection by the taxpayer or a related person; (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (e) the subject of a Ruling previously issued by the Directorate. ...

We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in the Ruling request is: (a) in an earlier return of the taxpayer or a related person; (b) being considered by a Tax Services Office or Taxation Center in connection with a previously filed tax return of the taxpayer or a related person; (c) under objection by the taxpayer or a related person; (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (e) the subject of a Ruling previously issued by the Directorate. ...