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We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling request herein are: (i) dealt with in an earlier return of Parentco, #Co, Aco, Bco, Cco, Canco or a related person; (ii) being considered by a tax services office or a taxation centre in connection with a tax return already filed by Parentco, #Co, Aco, Bco, Cco, Canco or a related person; (iii) under objection by Parentco, #Co, Aco, Bco, Cco, Canco or a related person; (iv) the subject of a previous ruling issued by the Income Tax Rulings Directorate to the taxpayers or a related person; nor, (v) before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

We understand that, to the best of your knowledge and that of the taxpayer, none of the issues involved in the ruling request is: (i) in an earlier tax return of the taxpayer 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 the taxpayer or a related person; (iii) under objection by the taxpayer or a related person; (iv) before the courts; or (v) the subject of a ruling previously issued by the Directorate to the taxpayer or a related person. ...

To the best of your knowledge and that of the above-referenced taxpayers, none of the issues involved in this ruling is: a) dealt with in an earlier tax return of the above-referenced 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 above-referenced taxpayers or a related person, c) under objection or appeal by the above-referenced taxpayers, or a related person, d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired, or e) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

We understand that, to the best of your knowledge and that of the taxpayer, none of the issues involved in this 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; or (v) is the subject of a Ruling previously issued by the Income Tax Rulings Directorate. ...

You have advised that to the best of your knowledge, and that of the above-referenced taxpayers involved, none of the issues contained herein is: (i) dealt with in an earlier tax return of the taxpayers or a related person; (ii) being considered by a tax services office or taxation centre in connection with any 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 or, if a judgment has been issued, the time limit for appeal to a higher court has expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in this ruling request is: (i) dealt with in an earlier return of the taxpayer or a related person; (ii) being considered by a Tax Services Office or a 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 judgment has been issued, the time limit for appeal to a higher court has expired, and (v) the subject of a previous ruling issued to the taxpayer or a related person by the Income Tax Rulings Directorate. ...

We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in this ruling are: (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 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 an appeal to a higher court has expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

To the best of your knowledge, and that of the taxpayer involved, none of the issues involved 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 judgment has been issued, the time limit for appeal to a higher court has expired; or (v) the subject of a ruling previously issued 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 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. ...

In addition, the return of capital described in Paragraph 69.1(c) will occur within XXXXXXXXXX months from the date of such disposition and no amount that can reasonably be considered to be derived from the proceeds of disposition of such property will have been paid by Subco 2 to Subco 1 on a previous reduction of the PUC in respect of any class of shares of Subco 2. 69.3 Subject to obtaining a ruling from XXXXXXXXXX, the Parent Group will undertake the Proposed Transactions and would do so even if the New Transactions were not being undertaken. ...