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To the best of your knowledge and the knowledge of the Companies, none of the issues involved in this request for an advance income tax ruling is: (a) in an earlier return of the Companies or of a person related to the Companies; (b) being considered by a tax services office or tax centre in connection with a previously-filed return of the Companies or of a person related to the Companies; (c) under objection by the Companies or by a person related to the Companies; (d) before the courts; nor (e) the subject of a ruling previously issued by the Income Tax Rulings Directorate to the Companies. ...

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. ...

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 taxpayers 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 taxpayers or a related person; (iii) is under objection by the taxpayers 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; You advised that to the best of your knowledge the proposed transactions described herein, will not impact the ability of the taxpayers to pay their outstanding tax liabilities. ...

We understand that, to the best of your knowledge and that of the Company, none of the issues involved in the ruling request is: (i) in an earlier return of the Company 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 Company or a related person, (iii) under objection by the Company 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; nor (v) the subject of a ruling previously issued by the Directorate. ...

Throughout this letter, the partnerships will be referred to as follows: XXXXXXXXXX the Partnership XXXXXXXXXX AAA We understand that, to the best of your knowledge, and that of the taxpayers involved, none of the issues contained in this advance income tax ruling: (a) is in an earlier return of the taxpayers or a related person; (b) is being considered by a tax services office or a taxation centre in connection with a previously filed tax return of the taxpayers or a related person; (c) is under objection by the taxpayers or related person; (d) is before the courts; or (e) is the subject of a ruling previously issued by the Directorate. ...

We understand that, to the best of your knowledge and that of the Corporation, none of the issues involved in the ruling request is: (i) in an earlier return of the Corporation 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 Corporation or a related person, (iii) under objection by the Corporation 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; nor (v) the subject of a ruling previously issued by the Directorate. ...

We understand that, to the best of your knowledge and that of the taxpayer referred to above, 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, 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 Directorate. ...

You have advised that to your knowledge as well as that of your client: a) none of the issues is in an earlier return of the taxpayer or related persons; b) none of the issues is being considered by a tax services office in connection with any previously filed tax returns; c) none of the issues is currently under objection; d) none of the issues is currently before any court; and e) none of the issues included is subject to a ruling request currently under consideration 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, and (v) is the subject of a ruling previously issued by the Directorate. ...

You have been advised by your clients that to the best of their knowledge, none of the issues involved in this ruling: (i) is in an earlier return; (ii) is being considered by a tax services office or taxation center in connection with a previously filed tax return; (iii) is under objection; (iv) is before the courts; or (v) is the subject of a previously issued ruling. ...