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To the best of your knowledge, and that of the taxpayer, none of the issues involved in this advance ruling is:- dealt with in an earlier return of the taxpayer or a related person;- being considered by a tax services office or a taxation centre in connection with a tax return already filed;- under objection by the taxpayer or a related person; or- before the courts. ... Each dissenting shareholder (a "DC dissenting shareholder") will cease to be a shareholder of DC, immediately prior to the transactions described in paragraphs 34 to 51, such that the shares of DC held by the DC dissenting shareholder, will no longer be considered to be outstanding. ...

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; (iv) is before the courts or, if a judgment 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. ... 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. ...

To the best of your knowledge and that of the taxpayers, none of the issues in this ruling request is: (i) involved in an earlier return of any 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 any of the taxpayers or a related person; (iii) under objection by any of the taxpayers or a related person; or (iv) before the courts. ... For greater certainty, the proposed transactions described herein, in and by themselves, will not be considered to result in any disposition or increase in interest described in any of subparagraphs 55(3)(a)(i) to (v). ...

We understand that to the best of your knowledge and that of the taxpayer involved, none of the issues contained herein: (i) is in an earlier tax return of the taxpayer 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 or a related person; (iii) is under objection by the taxpayer 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. ... The leading scenario being considered is building a mill that would be sized to the capacity of the underground mine. ...

You have advised us that to the best of your knowledge and that of the taxpayer involved none of the issues involved in this ruling request are: (i) in an earlier return of the taxpayer or any related person; (ii) being considered by a tax services office (TSO) or taxation centre (TC) in connection with a previously filed tax return by the taxpayer or any related person; (iii) under objection by the taxpayers or any 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. ... Under applicable generally accepted accounting principles, the transfers of the Portfolio, described in the Proposed Transactions, constitute related-party transactions that are not considered to be in the normal course of operations of the relevant transferor and hence will be recorded in the financial statements of the parties to the relevant transaction at the carrying amount of the Portfolio, not the exchanged amount (i.e., the fair market value of the Portfolio). ...

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 one 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 of the taxpayers or a related person; (iii) under objection by one 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 by the Income Tax Rulings Directorate. ... Provided that the conditions of subsection 74.4(4) are met the Share Exchange described in Paragraph 17 will not, in and by itself, be considered to benefit, either directly or indirectly, a designated person in respect of Individual A1 for the purposes of subsection 74.4(2). ...

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) 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, (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... In general, an acquisition of units of the Fund by investors in X, each of which would not be a Specified Shareholder of Target Holdco absent subclause 88(1)(c)(vi)(B)(II), will not necessarily be considered to occur as part of a series of transactions or events that includes the amalgamation of Target Holdco with Buyer Holdings. ...

We understand that, to the best of your knowledge, none of the issues involved in the 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 centre in connection with a previously filed tax return of the taxpayer or a related person, (iii) is under objection or appeal by the taxpayer or a related person, (iv) is before the courts or, if a judgment 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 Canada Revenue Agency. ... Provided that a Partner providing Professional Services to Newco through a Contracting Corporation would not, but for the existence of the Contracting Corporation, be an officer or employee of Newco in respect of those Professional Services, then each such Contracting Corporation will not be considered to be carrying on a personal services business as defined in subsection 125(7) of the Act. ...

To the best of your knowledge and that of the officers and directors of XXXXXXXXXX, none of the issues involved in this advance income tax ruling request is under objection or appeal or is being considered by any of the District Taxation Offices or Taxation Centres of Revenue Canada, Taxation (the "Department") in connection with any tax return already filed. ... Our favourable advance rulings as stated herein should not be considered as an indirect approval of any kind with respect to the possible operation of the price adjustment clauses referred to in paragraphs 21 and 25 above. ...

To the best of your knowledge and that of the Taxpayers, none of the issues involved in the ruling request is: i. in a previously filed tax 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 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. the subject of a current or completed court process involving the Taxpayers or a related person; or v. the subject of a ruling request previously considered by the Directorate. ...