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Reasons: In the first particular situation, the property sold is a personal use property of the corporation and the difference between the cost amount and the sale price of the property is considered to be the value of a benefit conferred on a shareholder on the basis of William H. ...

We understand that to the best of your knowledge and that of the taxpayers involved, none of the issues involved in the ruling request: (i) is an earlier return of the taxpayers or a related person; (ii) is being considered by a tax services office or a taxation centre in connection with a previous 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 judgement has been issued, the time limit for appeal has not expired; or (v) is the subject of a ruling previously issued by the Directorate. ...

We understand that, to the best of your knowledge and that of the Company, none of the issues involved in the ruling request (i) is in an earlier return of the Company or a related person, (ii) is being considered by a tax services office or taxation center 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 (v) is the subject of a ruling, other than the ruling referred to in 11 below, 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: (i) is in an earlier return of the taxpayer or a related person; (ii) is 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; (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 Applicants involved, none of the issues contained herein is: (i) dealt with in an earlier return of one or any the Applicants or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of one or any of the Applicants or a related person; (iii) under objection by one or any of the Applicants or a related person; (iv) is the subject of a ruling previously issued by the Income Tax Rulings Directorate except certain transactions XXXXXXXXXX; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

We understand that, to the best of your knowledge and that of the 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 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 Directorate to the taxpayer or a related person, except for the 2002 Ruling noted in paragraph 3, below; Unless otherwise stated, all references to a statute are to the Income Tax Act (Canada), R.S.C. 1985, c.1 (5th Supp.), as amended to the date of this letter, (the "Act"), and all terms and conditions used herein that are defined in the Act have the meaning given in such definition unless otherwise indicated. ...

To the best of your knowledge and that of ACo, CanSub 1, CanSub 2, CanSub 3, CanSub 4, TargetCo, Purchaser1, Purchaser2 and Purchaser3 (the "Parties"), none of the issues raised in the Ruling: 1. was identified in an earlier tax return of the Parties or any related persons; 2. is being considered by a tax services office or taxation centre in connection with a previously filed tax return of the Parties or any related person; 3. is under objection by any of the Parties or by any related person; 4. is before the courts; or 5. is the subject of a Ruling previously issued by the Income Tax Rulings Directorate of the CCRA issued to any of the Parties or any related person. ...

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 is: (i) in an earlier return of the taxpayer or a related person; (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 a related person; (iii) under objection by the taxpayers 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 not expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

The application of subsection 246(1) would have to be considered with respect to the automobiles used by the other individuals. ...

This package must, among other things, include: the conversion proposal and a summary of the expert opinions; a description of the advantages and disadvantages of demutualization to the company and its policyholders; a description of the alternatives to demutualization considered and the reasons why the directors of the company believe demutualization is in the best interests of the company and its policyholders; and a discussion of the tax treatment of demutualization benefits. ...