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We understand that, to the best of your knowledge, none of the issues raised in this ruling is being considered by a Taxation Services Office or Taxation Centre in connection with an income tax return already filed, is the subject of any notice of objection or is under appeal. ... In our view, in any period during which the First Nation has the authority respecting the geographic area of the Reserve, has acted or previously acted on, the authority to regulate in the areas typical of a municipality and continues to provide community services of the type in paragraphs 17 to 37 above, the First Nation will be considered to be a municipality in Canada within the meaning of paragraph 149(1)(c) of the Act and, accordingly, no tax will be payable under Part I by the First Nation on any dividends paid by the Company to which subsection 56(4) of the Act applies. ...

We also acknowledge the additional information in your letters of XXXXXXXXXX as well as your earlier correspondence dated XXXXXXXXXX We understand that, to the best of your knowledge and that of the directors and officers of XXXXXXXXXX/A, none of the issues raised in this ruling request is (i) in an earlier return of the taxpayer 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 taxpayer or a related person, (iii) under objection by the taxpayer 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 us. ... Provided that the shares of the subsidiaries of XXXXXXXXXX K and the shares of XXXXXXXXXX/H are capital property to XXXXXXXXXX/K and XXXXXXXXXX/B, respectively, prior to the Proposed Transactions, (i) none of the Proposed Transactions described herein will cause such shares to cease to be capital property to XXXXXXXXXX/K or XXXXXXXXXX/B, respectively, and (ii) the common shares of New XXXXXXXXXX/K issued to XXXXXXXXXX/K as consideration for the transfer of the shares of such subsidiaries and of XXXXXXXXXX/H, as described in paragraph 35(b) hereof, will be considered to be capital property to XXXXXXXXXX/K and Amalco 1. ...

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; or (iv) 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. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues involved in this request: (a) is involved in an earlier return of the taxpayer or a related person, (b) is being considered by a tax services office or taxation centre in connection with a tax return already filed by the taxpayer or a related person, (c) is under objection, (d) is before the courts or, if a judgement has been issued, the time limit for appeal has not expired, and (e) is the subject of a ruling previously issued by the Income Tax Rulings and Interpretations 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 contained herein: (i) is in an earlier return 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 the taxpayers or a related person; (iii) is under objection by the taxpayers 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 a ruling previously issued by the Directorate. ... For greater certainty, the proposed transactions described in paragraphs 5 to 12 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) of the Act. ...

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 DC, including the balance of its refundable dividend tax on hand, its capital dividend account and any losses available for carryforward, will not be considered property of DC for the purposes of the transactions described below. 21. ...

To the best of your knowledge none of the issues involved in this ruling request is being considered by a tax services office or taxation centre in connection with a tax return already filed or is under objection or appeal or the subject of any ruling, other than the First Ruling, previously issued by the Directorate with respect to the Debtor or Trustco. ... Provided the Purchased 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 money-lending business, all or any part of the Purchased Debt reacquired by the LENDER in circumstances described in 31 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, I. ...

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 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 the taxpayers or a related person, (iii) is under objection by the taxpayers 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, (v) is the subject of a ruling previously issued by the Directorate. ... THC will be considered to be carrying on business in Canada when it is a partner of the Production Partnership. ...

To the best of your knowledge, and that of the taxpayers involved, none of the matters considered in this ruling request are: (a) in an earlier return of the taxpayers or related persons; (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the taxpayers or related persons; (c) under objection by the taxpayers or related persons; (d) before the courts; or (e) the subject of a ruling previously issued by this Directorate to the taxpayers or related persons. ...

We understand that 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 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 the taxpayers or a related person; (iii)is under objection by the taxpayers 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; (v) is the subject of a ruling previously issued by the Directorates; or (vi) is being considered by a Revenue Canada Office in connection with a GSTIHST return already filed. ...