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To the best of your knowledge, the Corporation's knowledge and any Participants' knowledge, none of the issues involved in this ruling are: (i) in an earlier return of the Corporation or a Participant, or any person related to the Corporation or a Participant; (ii) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Corporation or a Participant, or any person related to the Corporation or a Participant; (iii) under objection by the Corporation or a Participant, or any person related to the Corporation or a Participant; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; nor (v) the subject of a ruling previously issued by the Directorate to the Corporation or a Participant. ...

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 any of the taxpayers 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 any of the taxpayers or a related person; (iii) under objection by any of 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 expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

We understand that to the best of your knowledge and that of the taxpayer involved none of the issues involved in the requested ruling is: (i) in an earlier return of a taxpayer identified in this document or of a related person, (ii) being considered by any Tax Services Office or Taxation Centre of the CRA in connection with a tax return already filed, (iii) under objection by a taxpayer identified in this document or by 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; and (v) is the subject of a previously issued ruling. ...

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, and (v) is the subject of a ruling previously issued by the Directorate. ...

To the best of your knowledge, and that of the parties to this ruling, none of the issues contained in this advance income tax ruling: 1. is in an earlier return of the taxpayer or a related person; 2. is being considered by a tax services office or a taxation centre in connection with a previously filed tax return of the taxpayer or a related person; 3. is under objection by the taxpayer or a related person; 4. is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or 5. is the subject of a ruling previously issued by this Directorate. ...

Jan Silden, 93 DTC 5362, the Federal Court of Appeal considered the issue of whether "at the time the loan was made... bona fide arrangements were made for repayment of the loan". ...

To the best of your knowledge and that of the taxpayers involved in this ruling request, 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 one or any of the taxpayers or a related person; (iii) under objection by one or any of the taxpayers 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 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 one or any of the taxpayers or a related person; (iii) under objection by one or any of the taxpayers 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. ...

Bco XXXXXXXXXX Cco XXXXXXXXXX Dco XXXXXXXXXX Eco XXXXXXXXXX Fco XXXXXXXXXX Gco XXXXXXXXXX Hco XXXXXXXXXX Ico We understand 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 any tax services office or taxation centre in connection with a tax return already filed, or is under objection or appeal. ...

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 judgement has been issued, the time limit for appeal to a higher court has not expired. ...