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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 the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations 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. ... Any tax accounts of Dco, such as the balance of any losses available for carryforward and its RDTOH, if any, will not be considered property of Dco for purposes of the proposed distribution described herein. 16. ...

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 district office or a taxation centre in connection with a tax return already filed, or is under objection or appeal. ... To the extent considered necessary, the memorandum and articles of XxXXXXXxXX will be amended to reflect the restrictions, prohibitions and limitations relating to the common shares of xxXXXxxxxx as set forth in the Depositary Agreement and the by Laws of XXXXXXXXXX will similarly reflect the arrangements set forth in the Depositary Agreement. 31. ...

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 any 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 any of the taxpayers or a related person; (iii)is under objection by the any of the taxpayers or a related person; or (iv)is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ... However, since certain of the transactions referred to in paragraph 5 above may be considered as occurring as part of the series of transactions or events which includes the winding-up of DC, the portion of the gain inherent in the shares of DC at the time of its winding-up will not be wholly attributable to the income earned or realized by DC before the safe-income determination time. ...

We understand that, to the best of your knowledge and that of the taxpayer, except to the extent described herein, none of the proposed transactions and/or issues in this letter are the same as or substantially similar to transactions and/or issues that are: (i) in a previously filed tax return of the taxpayer or a related person; (ii) being considered by a tax services office or tax 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) the subject of a current or completed court process involving the taxpayer or a related person; or (v) the subject of a ruling request previously considered by the Directorate. ...

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. ...

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 return of the Taxpayers or a related person; (b) 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; (c) under objection by the Taxpayers or a related person; (d) the subject of a current or completed court process involving the Taxpayers or a related person; or (e) the subject of a ruling previously considered by the Income Tax Rulings Directorate in relation to the Taxpayers or a related person. ...

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. ...

Except as disclosed in paragraph 7 hereof, to the best of your knowledge and that of the Taxpayers, none of the issues involved in the 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 a tax centre in connection with a tax return already filed by 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, if a judgment 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 Directorate to any of the Taxpayers or a related person. ... There is no “right to reduce” the interest on the Parent Loans and the interest is not otherwise “contingent” such that no portion of the interest on the Parent Loans will be considered to be a “contingent amount” as defined in Subsection 143.4(1) of the Act. 21. ...

To the best of your knowledge and that of the taxpayers involved, none of the proposed transactions or issues involved in this Ruling request are the same as or substantially similar to transactions or issues that are: i. in a previously filed tax return of the taxpayers or a related person and: A. being considered by the CRA in connection with such return; B. under objection by the taxpayers or a related person; or C. the subject of a current or completed court process involving the taxpayers or a related person; or ii. the subject of a Ruling request previously considered by the Income Tax Rulings Directorate. ...

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. ...