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Provided that the Loan arose from one or more loans or "lending assets", within the meaning of subsection 248(1) of the Act, made or acquired by the relevant Lender in the course of its insurance or money-lending business, any Loan reacquired by that Lender as described in 27 a) or b) above, will be considered to have been acquired by the Lender in the ordinary course of its business of insurance or lending money, as the case may be, for the purposes of paragraph 20(1)(l) and 20(1)(p) of the Act. ...

In other words, the subparagraph 75(2)(a)(i) condition would not be considered satisfied from the potential acquisition of the property from the spouse's estate in accordance with the spouse's will. ...

We understand that, to the best of your knowledge and that of the taxpayer, none of the issues involved in the ruling request is: (i) in an earlier return of the taxpayer 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) before the courts, or (v) the subject of a ruling previously issued by the Directorate to the taxpayer 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 this ruling is: (i) in an earlier return of a taxpayer identified in this document or of a related person, (ii) being considered by any Tax Services Office or Taxation Center of the CRA in connection with a tax return already filed, (iii) under objection by a taxpayer identified in this document 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 not expired, (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate to the taxpayer or a related person. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein: (i) is in an earlier return of one 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 one of the taxpayers or a related person; (iii) is under objection by one of 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; or (v) is the subject of a ruling previously issued by the Directorate. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained 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 one or any of the taxpayers or a related person; (iii) under objection by one or any of the taxpayers 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 involved, none of the issues contained herein: (i) is in an earlier tax 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 judgement has been issued, the time limit for appeal to a higher court has not expired; or (v) is the subject of an advance income tax ruling previously issued by the Income Tax Rulings Directorate (except Ruling 1 and Ruling 2, each as defined below). ...

You advise that to the best of your knowledge, and that of the taxpayers involved, none of the issues contained 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 one or any of the taxpayers or a related person; (iii) under objection by one or any of the taxpayers or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings Directorate; (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (vi) with respect to: (a) the Purchase Note as described in 16, 22 and 23 below, (b) the Class A Unitholder Notes as described in 32 below, (c) the exercise of the Call Option as described in 41 to 44 below, or (d) the payment of the subscription price by instalments as described in 32 below, dealt with in any documents or any agreements (either verbal or written), other than the documents and agreements that have been submitted to the Income Tax Rulings Directorate in draft form in connection with this advance ruling and that further, both you and the taxpayers involved have made enquiries with respect to whether any such additional documents or agreements exist or will exist. ...

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 taxation 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 Holdco and Opco, none of the issues contained herein: (a) is in an earlier return of Holdco or Opco 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 Opco or a related person; (c) is under objection by Holdco or Opco 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 and Interpretations Directorate of Revenue Canada. ...