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In that case, the application of subsections 13(21.2) and 40(3.4) would have to be considered. ...

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. ...

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 a taxpayer or a related person; (ii) is being considered by a tax services office or taxation centre in connection with a previously filed tax return of a taxpayer or a related person; (iii) is under objection by a 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 taxpayers involved, none of the issues involved with this request: (i) is involved in 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 tax return already filed by the taxpayer or a related person; (iii) is under objection; or (iv) is before the courts or, if a judgement has been issued, the time limit for appeal has not expired. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues involved in this ruling (a) is in an earlier return of the taxpayer(s) 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 the taxpayer(s) or a related person, (c) is under objection by the taxpayer(s) 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, and (e) is the subject of a ruling previously issued by Revenue Canada, the Canada Customs and Revenue Agency or CRA. ...

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

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 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 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 taxpayers, none of the issues involved in the Ruling request: (i) is in an earlier return of the Corporation, the Employer or a related person, (ii) is being considered by a Tax Services Office or a Taxation Center in connection with a previously filed return of the Corporation, the Employer or a related person, (iii) is under objection by the Corporation, the Employer or a related person, (iv) is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has expired, or (v) is the subject of a Ruling previously issued by the Directorate to the Corporation, the Employer or a related person. 29. ...

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. ...