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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. ...

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

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. ...

To the best of your knowledge and that of the Corporation, none of the issues involved in this ruling are: i) in an earlier return of the Corporation, 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, a Participant, or any person related to the Corporation or a Participant; iii) under objection by the Corporation, 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 not expired; nor v) the subject of an income tax ruling previously issued by CCRA to the Corporation. ...