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You advise that to the best of your knowledge and that of the taxpayers noted above, none of the issues involved in the ruling request has been considered by a taxation services office or a taxation centre in connection with a tax return already filed, and none of the issues involved in the ruling request is the subject of any notice of objection or is under appeal. ... K.Provided that the Debt arose from one or more loans or "lending assets", within the meaning of subsection 248(1) of the Act, made or acquired by the Lender in the course of its insurance or money lending business, the Debt reacquired by the Lender as described in paragraph 41 above will be considered to have been acquired by the Lender in the ordinary course of its business of lending money for the purposes of paragraphs 20(1)(l) and 20(1)(p) of the Act. ...

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 taxation services office or a taxation centre in connection with a tax return already filed, or is under objection or appeal. ... Aco has engaged XXXXXXXXXX to determine the portion of the unrealized capital gain inherent in the XXXXXXXXXX Bco Shares, the XXXXXXXXXX Bco Shares and the XXXXXXXXXX Bco Shares owned by Aco that can reasonably be considered to be attributable to the income earned or realized, within the meaning of paragraph 55(5)(b), by Bco before the "safe income determination time" as that term is proposed to be defined in subsection 55(1) (such income being referred to hereinafter as "Safe Income on Hand") attributable to each of the XXXXXXXXXX Bco Shares, the XXXXXXXXXX Bco Shares and the XXXXXXXXXX Bco Shares owned directly by Aco, and the Safe Income on Hand attributable to each of the Subco Bco Shares owned by Subco. ...

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 tax services office or a taxation centre in connection with a tax return already filed, or is under objection or appeal. ... For greater certainty, any tax accounts, such as the balance of any RDTOH account or capital dividend account of Amalco, will not be considered property for purposes of the proposed transactions described herein. 14. ...

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 judgement has been issued, the time limit for appeal to a higher court has not expired. ... For greater certainty, any tax accounts of Opco, such as the balance of any losses available for carryforward, will not be considered property of Opco for purposes of the proposed transactions set out herein. 19. ...

To the best of your knowledge, and that of the taxpayers, none of the issues involved in the ruling request 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 tax return previously filed by the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) before the courts and there is no judgment that has been issued in which the time limit for appeal to a higher court has not expired; and (v) the subject of a ruling previously issued by the Income Tax Rulings and Interpretations Directorate. ... For greater certainty, any tax accounts, such as the balance of any non-capital losses, RDTOH or CDA of Opco, will not be considered property for purposes of the proposed transactions described herein. 15. ...

We understand that 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 judgement has been issued, the time limit for appeal to a higher court has expired; and (v) is the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... For greater certainty, any tax accounts, such as balances of any capital losses, non-capital losses, Pre-1972 CSOH, Capital Dividend Account or RDTOH of DCO, will not be considered to be a property for purposes of the proposed transactions described herein. ...

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). ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in this ruling is: a. in an earlier 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. before the courts, or e. the subject of a ruling previously issued by this Directorate. ... The provisions of subsection 69(11) will not apply to the transfer of certain assets of BusinessA to PartnershipA as described in paragraph 27 above or to the transfer by XCO of its interest in PartnershipA to Aco as described in paragraph 42 above, unless there is a subsequent disposition (or arrangements are made for the subsequent disposition) of (i) the assets which are transferred to PartnershipA or (ii) the interest in PartnershipA or (iii) property substituted for property described in (i) or (ii), within 3 years after the transfers described in paragraphs 27 and 42 above and where it may reasonably be considered that one of the main purposes of the series of transactions or events (which includes the subsequent disposition of the assets, the interest in PartnershipA or properties substituted therefor) is to obtain a benefit of any item described in paragraphs 69(11)(a) or (b) which is available to a person (other than a person that is affiliated with XCO immediately before the series began). ...

Nothing in the Plan shall be considered as creating a trust or creating any fiduciary relationship. ... To the best of your knowledge and that of the Parent, the Corporation and the Employee, none of the issues involved in this ruling are: i) in an earlier return of the Corporation or the Employee, or any person related to the Corporation, the Employee or a Participant; ii) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Corporation, the Employee or a Participant, or any person related to the Corporation, the Employee or a Participant; iii) under objection by the Corporation, the Employee, a Participant, or any person related to the Corporation, the Employee or a Participant; iv) before the courts; nor v) the subject of an income tax ruling previously issued by CCRA to the Corporation, the Employer or a Participant. ...

To the best of your knowledge and that of Aco, 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 greater certainty, the facts and 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). ...