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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: (i) is in an earlier return of the taxpayers 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 taxpayers or a related person; (iii) is under objection by the taxpayers or a related person; or (iv) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...

We understand that, to the best of your knowledge and that of the taxpayer involved, none of the issues involved in this 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; or (iv) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...

PAYMENTS TO A FORMER PARTNER IN RESPECT OF GOODWILL AND WORK IN PROGRESS Work in progress (WIP) and goodwill, like other properties of a partnership, are considered to be owned by the partnership for tax purposes. ...

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. ...

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 any of the 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 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 not expired; or v. the subject of a ruling previously issued by the Directorate to any of the Taxpayers or a related person. ...

We understand that none of the issues involved in the ruling request, to the best of your knowledge and that of the taxpayers involved: i) is in an earlier return of the taxpayers or a related person, ii) is being considered by an office of Revenue Canada 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 judgement 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 taxpayers or a related person. ...

ADDITIONAL INFORMATION 40.To the best of your knowledge, and that of the parties to this ruling, none of the issues involved in the requested rulings is being considered by a tax services office or a taxation centre in connection with an income tax return already filed, or is under objection or appeal. 41.There will not be, as part of the series of transactions or events that includes the proposed transactions described herein, any (a) disposition of property in the circumstances described in subparagraph 55(3.1)(b)(i), (b) acquisition of control in the circumstances described in subparagraph 55(3.1)(b)(ii), (c) acquisition of property in the circumstances described in paragraph 55(3.1)(c), (d) acquisition of property in the circumstances described in paragraph 55(3.1)(d), which has not been described herein. 42.Other than as a result of the proposed amalgamation of the Subject Corporations described in paragraph 28 of Proposed Transactions, no property has or will become property of any of the Subject Corporations or Amalco in contemplation of the proposed transactions. 43.None of the shares referred to in this ruling application is or will be subject to a guarantee agreement, within the meaning of subsection 112(2.2) of the Act, that is given by a person or partnership (other than the issuer of the share or an individual other than a trust), that is a specified financial institution or a specified person in relation to such an institution. 44.None of the shares described herein have been or will be issued or acquired as part of a transaction or event or series of transactions or events of the type described in subsection 112(2.5) of the Act. 45.None of the shares described herein has been or will be the subject of a dividend rental arrangement as that term is defined in subsection 248(1) of the Act. ...

We understand that none of the issues involved in the ruling request, to the best of your knowledge and that of the taxpayers involved: i) is in an earlier return of the taxpayers or a related person, ii) is being considered by an office of Revenue Canada 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 judgement 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 taxpayers 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 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. ...

To the best of your knowledge and the knowledge of the responsible officers of the taxpayers involved none of the issues involved in the requested rulings is being considered by a Tax Services Office or Taxation Centre in connection with an income tax return already filed and none of the issues involved is subject to a notice of objection under section 165 of the Income Tax Act or is otherwise under appeal. ...