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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 request is: (a) dealt with in an earlier return of any of the taxpayers or a related person, (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of any of the taxpayers or a related person, (c) under objection by any of the taxpayers or a related person, (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired, or (e) the subject of a ruling previously issued to any of the parties or a related person by the Income Tax Rulings Directorate of the Canada Revenue Agency Our understanding of the facts, proposed transactions, other representations and the purpose of the proposed transactions are as follows: DEFINITIONS In this letter, unless otherwise expressly stated, the following terms have the meanings specified hereunder: (a) "ABL Credit Facility" means a senior secured credit facility denominated in XXXXXXXXXX between Opco, as borrower, and certain First Lien Lenders, as lenders. ...

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 judgement has been issued, the time limit for appeal to a higher court has expired; and (v) is the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

To the best of your knowledge, and that of the Taxpayers, none of the issues involved in this advance income tax ruling are: (i) in an earlier tax return of the Taxpayers or of a related person; (ii) being considered by a Tax Services Office or a Taxation Centre in connection with a previously-filed tax return of the Taxpayers or of a related person; (iii) under objection by the Taxpayers or by 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, other than the Initial Ruling, previously issued to the Taxpayers or a related person by the Income Tax Rulings Directorate. ...

MNR, 68 DTC 5180, the court stated: In the absence of any definition in the statute of the expression “capital cost to the taxpayer of property” and in the absence of any authoritative interpretation of those words as used in Section 11(1)(a), insofar as they are being considered with reference to the acquisition of capital assets, I am of opinion that they should be interpreted as including outlays of the taxpayer as a business man that were the direct result of the method he adopted to acquire the assets. ...

We understand that, to the best of your knowledge and that of the Taxpayers, none of the issues involved in the ruling request is: (i) 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 Taxpayers or a related person, (iii) under objection by the Taxpayers or a related person, or (iv) before the courts. ...

To the best of your knowledge and that of each of the taxpayers, none of the issues involved in this ruling request is: in an earlier return of any of the taxpayers or a related person; being considered by a tax services office or taxation centre in connection with a previously filed tax return of any of the taxpayers or a related person; under objection by any of the taxpayers or a related person; before the courts; or the subject of a ruling previously issued by the Income Tax Rulings Directorate other than the advance income tax ruling issued on XXXXXXXXXX, 2006 (our reference 2006-020398) (the "Original Ruling") and the advance income tax ruling issued on XXXXXXXXXX, 2007 (our reference 2007-0232261R3)(the "Second Ruling"). ...

" " 20 " "Modification" is considered to be merely a partial alteration of a pre-existing thing. ...

To the best of your knowledge, and that of the above-noted taxpayers, none of the issues involved in this advance income tax ruling request are: (i) in an earlier return of any of the above-noted taxpayers or a related person; (ii) being considered by a Tax Services Office or a Taxation Centre in connection with a previously-filed tax return of any of the above-noted taxpayers or a related person; (iii) under objection by any of the above-noted 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 to any of the above-noted taxpayers by the Income Tax Rulings Directorate. ...

To the best of your knowledge, and that of the Taxpayers, none of the issues involved in this advance income tax ruling are: (i) in an earlier return of any of the Taxpayers or a related person; (ii) being considered by a Tax Services Office or a Taxation Centre 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 to any of the Taxpayers by the Income Tax Rulings Directorate. ...

We also acknowledge the additional information provided in your subsequent correspondence dated XXXXXXXXXX We understand that, to the best of your knowledge and that of the taxpayers, none of the issues involved in the ruling request is: a) in an earlier tax return of the taxpayers or of any related persons; b) being considered by a tax services office or a tax centre in connection with a tax return already filed by the taxpayers or by any related persons; c) under objection by the taxpayers or any related persons; d) before the courts or, e) the subject of a ruling previously issued by the Directorate to the taxpayers or to any related persons. ...