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To the best of your knowledge, and that of the taxpayers named herein, none of the issues involved in this advance income tax ruling request is under objection or appeal or is being considered by any tax services office or taxation centre of Revenue Canada in connection with any income tax return already filed. ...

We understand that, to the best of your knowledge and that of the Taxpayers, none of the proposed transactions and/or issues involved in this ruling are the same as, or substantially similar to, transactions and/or issues that are: a. in a previously filed tax return of the Taxpayers or person related to the Taxpayers; b. being considered by the CRA in connection with a previously filed tax return of the Taxpayers or a person related to the Taxpayers; c. under objection by the Taxpayers or a person related to the Taxpayers; 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 an advance income tax ruling previously issued by the Income Tax Rulings Directorate of the CRA in connection with the Taxpayers or a person related to the Taxpayers. ...

Il a fait les commentaires suivants: «It is my understanding that in those circumstances, that is a part-time personal use of a yacht, the Minister of National Revenue considered that the proper method of evaluating the benefit was by allocating operating costs. ...

You have advised that to the best of the knowledge of the responsible officers of each of the Applicants and yourselves, none of the issues involved in this Ruling: is in an earlier tax return of any of the Applicants or a related person; (i) is being considered by a tax services office or taxation centre in connection with a previously filed tax return or of any of the Applicants or a related person; (ii) is under objection by any of the Applicants or a related person; (iii) is before the courts; or (iv) is the subject of a ruling previously issued by the Income Tax Rulings Directorate of Canada Customs and Revenue Agency ("CCRA") You have advised that to the best of the knowledge of the responsible officers of each of the Applicants, the Proposed Transactions will not have any impact on existing outstanding tax liabilities, if any, of any of the Applicants. ...