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., C Ltd. or a related person; (b) is being considered by a tax services office or taxation centre in connection with a previously filed return of M Ltd., C Ltd., or a related person; (c) is under objection by M Ltd., C Ltd., or a related person; (d) is before the courts or, if a judgement 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 Directorate of the Canada Customs and Revenue Agency. ... The filing of Articles of Amendment by M Ltd., as described in paragraph 27.1 above, will not cause a "disposition" (within the meaning of that term in subsection 248(1)) by the holders of the Class B Non-Voting Common Shares in M Ltd. of their existing shares, nor will it be considered an "acquisition" of new shares by such holders for the purposes of section 116. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in this ruling request is (i) involved 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 judgement 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 Income Tax Rulings Directorate. ... For greater certainty, the proposed transactions described in paragraphs 10 to 20 above, 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). ...

To the best of your knowledge, and that of any of the taxpayers, none of the issues involved 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). ...

You have advised us 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 the taxpayers or a related person; (ii) being considered by a tax services office ("TSO") or taxation centre ("TC") 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; (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (iv) the subject to a ruling previously issued by the Income Tax Rulings Directorate. ... 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). ...

You advise that to the best of your knowledge and that of the taxpayers referred to above, none of the issues involved in the ruling request is: i. in an earlier return of the taxpayers or related persons; ii. being considered by a tax services office or taxation centre in connection with a previously filed return of the taxpayers or related persons; iii. under objection by the taxpayers or related persons; 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 previous ruling issued by the Income Tax Rulings Directorate. ... If the CCRA were to issue a reassessment to ACO in this regard and the courts were to dismiss any appeal by ACO, BCO has agreed to indemnify ACO for any resulting loss to ACO. 24) The CCRA has not considered and therefore expresses no opinion as to the tax implications related to the asset purchase agreement referred to in 8 and 10 above beyond the specific rulings provided below. ...

You have been advised by your clients that to the best of their knowledge, none of the issues discussed in this ruling: a. is in an earlier return; b. is being considered by a Tax Services Office or a Taxation Centre in connection with a previously filed tax return; c. is under objection; d. is the subject of a previously issued ruling; or e. is before the courts. ... For greater certainty, any tax accounts will not be considered property for purposes of the proposed transactions described herein. 26. ...

To the best of your knowledge and that of Aco, none of the issues involved in this request for an advance income tax ruling: (a) is being considered by a tax services office or taxation centre in connection with a previously filed return of Aco or a person related to Aco; (b) is under objection by Aco or a person related to Aco; or (c) is before the courts or if, a judgment has been issued, the time limit for appeal to a higher court has not expired. ... These comments are provided in accordance with the guidelines set out in paragraph 22 of IC 70-6R5 and are not considered binding on the CCRA. ...

To the best of your knowledge and that of the parties to this ruling, none of the issues in this 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 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, any tax accounts, such as the balance of RDTOH, pre-1972 CSOH, or capital dividend account of Aco will not be considered property for purposes of the proposed transactions. 17. ...

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 Directorate. ... Provided that a former Partner providing professional services to Newco through a Contracting Professional Corporation would not, but for the existence of the Contracting Professional Corporation, be an officer or employee of Newco in respect of those professional services, then each such Contracting Professional Corporation will not be considered to be carrying on a "personal services business" as defined by subsection 125(7) of the Act. ...

Reasons: 1) Losses allocated under the master and lower-tier partnerships during the first four years will not exceed 99% of the cost of the partnership units; 2) Meets the requirements of section 54.2; 3) Meets the requirements of subsection 98(3); 4) The partitioning complies with subsection 248(21) of the Act; 5) The conversion complies with subsection 51(1) of the Act; 6) GAAR not applicable as it may reasonably be considered that the proposed transactions do not misuse any provisions of the Act or abuse the Act read as a whole. ... To the best of your knowledge, and that of the general partner of the Offering Partnership, none of the issues contained in this ruling request is: (i) dealt with in an earlier return of any prospective member of the Offering Partnership 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 prospective member of the Offering Partnership or a related person; (iii) under objection or appeal by any prospective member of the Offering Partnership or a related person; or (iv) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has expired. ...