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To the best of your knowledge and that of ACO, none of the issues involved in this ruling: (a) is in an earlier return of ACO 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 ACO or a related person; (c) is under objection by ACO or a related person; (d) is before the courts; or, (e) is the subject of a ruling previously issued by the 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 to an unrelated person as described in subparagraphs 55(3)(a)(i) to (v). ...

There are no significant transactions that were completed by the Company that may be undertaken after the adoption of the Plan that might be considered to be part of the series of transactions of which the Plan is part. 7. To the best of your knowledge, none of the issues involved in this ruling are: i) in an earlier return of the Company, a Participant, or any person related to the Company or a Participant; ii) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Company, a Participant, or any person related to the Company or a Participant; iii) under objection by the Company, a Participant, or any person related to the Company or a Participant; iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; nor v) the subject of a ruling previously issued by the Directorate to the Company, other than the Rulings. ...

You have advised that to the best of your knowledge, and that of the taxpayers named herein, none of the issues involved in this advance income tax ruling is under objection or appeal or is being considered by any tax services office or taxation centre in connection with any income tax return already filed. ... 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 to an unrelated person as described in subparagraphs 55(3)(a)(i) to (v). ...

We understand that, to the best of your knowledge and that of Purchaser ("the taxpayer"), none of the issues involved in the ruling request: (i) is identified in an earlier tax return of the taxpayer or of 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; and (v) is the subject of a ruling previously considered by the Income Tax Rulings Directorate. ...

Whether a shareholder group of a widely held public company can be considered to be a group acting in concert to control a company as a result of supporting a decision (i.e. voting on the acceptance of an acquisition of another company). 2. ... To the best of the knowledge of the responsible officers of Bco and yourselves, none of the issues involved in this Ruling Request: (i) is in an earlier tax return of Bco 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 Bco or a related person; (iii) is under objection by Bco 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 Income Tax Rulings Directorate of the CCRA. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues involved in this ruling (i) is in an earlier return of the taxpayer(s) 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(s) or a related person, (iii) is under objection by the taxpayer(s) 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 Revenue Canada or the Canada Customs and Revenue Agency (the "CCRA"). ... The carrying out of the proposed transactions described above, including the license of the Canadian Rights by Aco pursuant to the Canadian License, will not result in Aco being considered to have disposed of an ownership interest in its portion of the Series, for the purposes of section 125.4 and paragraph 20(1)(a). ...

We understand that, to the best of your knowledge and that of the taxpayer involved, 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 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 Revenue Canada or the Canada Customs and Revenue Agency ("CCRA"). ... The granting of the rights under the Canadian Licence by CanCo-Producer to the UK Co-Producer will not be considered a disposition of the copyright in the Film by CanCo-Producer for the purposes of section 125.4 of the Act. ...

We understand 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 one of the taxpayers or a related person; (ii) under objection by the above-noted taxpayer or others identified herein or a related person; (iii) being considered by a Tax Services Office or taxation centre in connection with a tax return already filed of any one of the taxpayers or a related person; (iv) the subject of 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. ... For greater certainty, any tax accounts of DC, such as the amount of RDTOH or any deferred income tax debit balance, will not be considered property for purposes of the classification described in this paragraph. 12. ...

We understand that, to the best of your knowledge and that of the taxpayer involved, 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 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 Revenue Canada or the Canada Customs and Revenue Agency ("CCRA"). ... The granting of the rights under the Canadian Licence by Can Co-Producer to the UK Co-Producer will not be considered a disposition of the copyright in the Series by Can Co-Producer, for the purposes of section 125.4. ...

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; (iv) before the courts; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... For purposes of subsections 111(4), (5), (5.1), (5.2) and 249(4), Parentco will be considered to have acquired control of Lossco at the commencement of XXXXXXXXXX. ...