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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 a taxpayer identified in this document or of a related person, (ii) is being considered by any Tax Services Office or Taxation Centre of the Agency in connection with a tax return already filed, (iii) is 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 issues, the time limit for appeal to a higher court has not expired, and Unless otherwise stated, all references to a statute are to the Income Tax Act R.S.C. 1985 (5th Supp.), c.1, as amended, (hereinafter the "Act") and all terms and conditions used herein that are defined in the Act have the meaning given in such definition unless otherwise indicated. ...

We understand that 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 a tax services office or a taxation centre in connection with a tax return already filed, or is under objection or appeal. ...

We understand that 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 a tax services office or a taxation centre in connection with a tax return already filed, or is under objection or appeal. ...

We understand that, to the best of your knowledge, and that of the taxpayers on whose behalf this ruling is requested none of the issues contained in this advance income tax ruling are: i) contained in earlier returns of the taxpayers or a related person; ii) being considered by a tax service office and/or a tax centre in connection with a tax return previously filed by the taxpayers or a related person; iii) under objection by the taxpayers or related person; iv) before the courts; or v) the subject of a ruling previously issued by the Directorate to the taxpayers or a related person. ...

To the best of your knowledge, and that of any of the taxpayers, none of the issues involved in this ruling request is: (i) involved in an earlier return of any of the taxpayers or a related person; (ii) being considered by a tax services office or taxation centre in connection with a tax return previously filed by any of the taxpayers or a related person; (iii) under objection by any of the taxpayers or a related person; (iv) before the courts and there is no judgment that has been issued in which the time limit for appeal to a higher court has not expired; and (v) the subject of a ruling previously issued by the Income Tax Rulings and Interpretations Directorate. ...

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. ...