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We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in this ruling (i) is in an earlier return of the taxpayer(s) 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 the taxpayer(s) or a related person, (iii) is under objection by the taxpayer(s) 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 Revenue Canada or the Canada Customs and Revenue Agency. ...

We understand that to the best of your knowledge and that of Holdco, none of the issues involved herein: (a) is in an earlier return of Holdco 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 Holdco or a related person; (c) is under objection by Holdco 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; or (e) is 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 XXXXXXXXXX/Aco, XXXXXXXXXX/Bco, XXXXXXXXXX/Mother and XXXXXXXXXX/Child 1 none of the issues contained herein: (a) is in an earlier return of XXXXXXXXXX/Aco, XXXXXXXXXX/Bco, XXXXXXXXXX/Mother or XXXXXXXXXX/Child 1 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 XXXXXXXXXX/Aco, XXXXXXXXXX/Bco, XXXXXXXXXX/Mother or XXXXXXXXXX/Child 1 or a related person; (c) is under objection by XXXXXXXXXX/Aco, XXXXXXXXXX/Bco, XXXXXXXXXX/Mother or XXXXXXXXXX/Child 1 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; or (e) is the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

We understand that to the best of the knowledge of the taxpayers involved and XXXXXXXXXX, 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 centre 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 Rulings Directorate. ...

You advise that, to the best of your knowledge and that of the parties involved, none of the issues described herein is being considered by a Tax Services Office or a Tax Centre in connection with any tax return already filed or is the subject of any notice of objection or is under appeal. ...

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 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. ...

We understand that to the best of your knowledge and that of the taxpayers, none of the issues involved in this ruling request: (a) are in an earlier return of the taxpayers or a related person; (b) are being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or a related person; (c) are under objection by the taxpayers or a related person; (d) are before the courts; or (e) are the subject of a ruling previously issued by this Directorate to the taxpayers or a related person. ...

We understand that, to the best of your knowledge and that of the above-named taxpayers, none of the issues involved in the ruling request is: (i) in an earlier tax return of the above-named taxpayers or a related person; (ii) being considered by a tax services office or a tax centre in connection with a tax return already filed by the above-named taxpayers or a related person; (iii) under objection by the above-named 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 Directorate to the above-named taxpayers or a related person. ...

We understand that to the best of your knowledge and that of each of the Taxpayers involved, none of the issues described herein are: (a) in a previously filed tax return of the Taxpayers or person related to the Taxpayers; (b) being considered by the CRA in connection with a previously filed tax return of the Taxpayers or a person related to the Taxpayers; (c) under objection by the Taxpayers or a person related to the Taxpayers; (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; and (e) the subject of an advance income tax ruling previously issued by the Income Tax Rulings Directorate of the CRA in connection with the Taxpayers or a person related to the Taxpayers. ...

When would a taxable dividend designated in respect of a beneficiary of a trust pursuant to subsection 104(19) be considered to have been received by the beneficiary? ...