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To the best of the Company's and your knowledge, none of the issues involved in this Ruling are: (a) in an earlier tax return of the Company, a Participant or any person related to the Company or a Participant; (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Company, a Participant or any person related to the Company or a Participant; (c) under objection by the Company, a Participant or any person related to the Company or a Participant; (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; or (a) (e) except as noted in the next paragraph, the subject of an advance income tax ruling previously issued by the Directorate to the company, a Participant, or any person related to the Company or a Participant. 18. ...

To the best of your knowledge, and that of the taxpayer, none of the issues in this ruling request is: (i) involved 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) before the courts; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

These elements should be considered in examining the purpose of section 84.1. ...

We understand that, to the best of your knowledge and that of the above-referenced taxpayer, none of the issues involved in the ruling request is: (i) in an earlier return of the taxpayer or a related person; (ii) 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; (iii) under objection by the taxpayer or a related person; (iv) before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has expired; or (v) the subject of a ruling previously issued to the taxpayer or a related person, XXXXXXXXXX, by this Directorate. ...

To the best of your knowledge and that of the taxpayers, none of the issues in this ruling request is: (i) being considered by a tax services office or taxation centre in connection with a previously filed tax return of any of the taxpayers or a related person; (ii) under objection by any of the taxpayers or a related person; or (iii) before the courts. ...

You have advised us that to the best of your knowledge and that of the taxpayers involved none of the issues involved in this ruling request are: (i) in an earlier return of the taxpayers or related persons; (ii) being considered by a tax services office ("TSO") or taxation centre ("TC") in connection with a previously filed tax return of the taxpayers or related persons; (iii) under objection by the taxpayers or related persons; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

Nothing in this Supplementary Advance Income Tax Ruling should be construed as implying that we are ruling on, or have considered, or discussed with you any tax consequences relating to the changes to proposed transactions. ...

However, where it is apparent at the time the loan is made that the corporation receiving the funds will not be in a position to repay the loan or to provide reasonable security for repayment, the shareholder who has directed the payment may be considered to have deliberately and permanently removed value from the corporation. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling request are: (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 to the taxpayers or a related person 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 acknowledge the additional information received on XXXXXXXXXX To the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling request are: (i) dealt with in an earlier tax return of A Co or a related person; (ii) 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) under objection by the A Co or a related person; (iv) before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings and Interpretation Directorate of the Canada Revenue Agency ("CRA"). ...