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The DC Subco common shares and the DC Subco Promissory Note will be considered as cash for all purposes hereof and will be distributed to the parties as cash in the implementation of the transactions described herein. ...

We understand that, to the best of your knowledge and that of the taxpayers, none of the issues involved in the ruling request are: (i) in an earlier return of any of the taxpayers or related persons, (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of any of the taxpayers or related persons, (iii) under objection by any of the taxpayers or related persons, (iv) before the courts, or (v) the subject of a ruling previously issued by the Directorate to any of the taxpayers or related persons. ...

We understand that to the best of your knowledge and that of the taxpayers involved, none of the issues involved in this letter is: (i) involved 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, (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 by the Income Tax Rulings Directorate (other than Letter XXXXXXXXXX, Ruling XXXXXXXXXX and Letter XXXXXXXXXX). ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in this 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; (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 by the Income Tax Rulings Directorate. ...

You have advised us that to the best of your knowledge and that of the Taxpayers, none of the issues involved in this ruling request are: (i) in an earlier return of the Taxpayers or any person who is related to the Taxpayers; (ii) being considered by a tax services office or taxation centre in connection with a tax return filed previously by any of the Taxpayers or any person who is related to any of the Taxpayers; (iii) under objection by any of the Taxpayers or any person who is related to the any of the Taxpayers; (iv) before the courts; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

Although the Court in Sedona Networks appears to have implicitly considered that paragraph 251(5)(b) must be applied by simultaneously considering the rights held by all persons, it has not explicitly disregarded CRA's reliance on a selective application of that provision to challenge avoidance schemes intended to circumvent the statutory limitations applicable to the CCPC definition. ...

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. ...

Nothing in this Advance Income Tax Ruling should be construed as implying that we are ruling on, or have considered, or discussed with you any tax consequences relating to the facts and proposed transactions described herein other than those specifically described in the Rulings given above. ...

You have advised us that to the best of your knowledge, and that of the Taxpayers, none of the issues contained herein is: (a) in an earlier return of a Taxpayer or a person related to a Taxpayer; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of a Taxpayer or a person related to a Taxpayer; (c) under objection by a Taxpayer or a person related to a Taxpayer; (d) the subject of a ruling (other than the Existing Ruling) previously issued by the Income Tax Rulings Directorate; or (e) before the Courts. ...

We understand that to the best of your knowledge and that of the taxpayers involved, none of the issues described 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 the taxpayers or a related person, (iii) under objection by 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 by the Income Tax Rulings Directorate. ...