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To the best of your knowledge and that of the taxpayer, none of the issues involved in the ruling request is: (i) dealt with in an earlier tax return of the taxpayer or a person (a "specified person") who is a person related to the taxpayer or a Participant in the Plan referred to below; (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 specified person; (iii) under objection by the taxpayer or a specified 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 Directorate, other than Ruling 2003-0040931 dated XXXXXXXXXX and Ruling 2007-0246431 dated XXXXXXXXXX. ...

To the best of your knowledge, and that of the above-noted taxpayers, none of the issues involved in this advance income tax ruling are: (i) in an earlier tax return of the above-noted taxpayers or of 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 above-noted taxpayers or of a related person; (iii) under objection by the above-noted taxpayers or by 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 above-noted taxpayers or a related person. ...

To the best of your knowledge, and that of the Taxpayers, none of the issues involved in this advance income tax ruling are: (i) in an earlier tax return of the Taxpayers or of 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 Taxpayers or of a related person; (iii) under objection by the Taxpayers or by 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 Taxpayers or a related person. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling request 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 of Canada Revenue Agency ("CRA") 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 Directorate to the taxpayers or a related person; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

To the best of your knowledge and that of Parent, none of the proposed transactions involved in this ruling letter: (i) is in an earlier return of Parent or any persons related to Parent, (ii) is being considered by a tax services office or taxation centre in connection with a previously filed tax return of Parent or any persons related to Parent, (iii) is under objection by Parent or any persons related to Parent, 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. ...

We understand that to the best of your knowledge and that of the taxpayers involved, none of the issues involved in this ruling request herein is: (i) in a return of the Trust, ACo 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 Trust, ACo or a related person; (iii) under objection by the Trust, ACo or a related person; (iv) the subject of a ruling previously issued by the Income Tax Rulings Directorate of the CRA to the Trust or ACo, or a related person, XXXXXXXXXX; nor (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling request 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 of Canada Revenue Agency ("CRA") 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 Directorate to the taxpayers or a related person; or (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 taxpayers involved, none of the issues contained in this ruling request herein are: (i) dealt with in an earlier return of Lossco, Profitco, 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 Lossco, Profitco, or a related person; (iii) under objection by Lossco, Profitco, or a related person; (iv) the subject of a previous ruling issued by the Income Tax Rulings Directorate to Lossco, Profitco, 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. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling is: (a) in a previously filed income tax return of any of the taxpayers or a related person; (b) being considered by a Tax Services Office or a tax centre in connection with a previously filed income tax return of any of the taxpayers or a related person; (c) under objection by any of the taxpayers or a related person; (d) before the courts; or (e) the subject of a ruling previously issued by the Income Tax Rulings Directorate involving any of the taxpayers or a related person. ...

To the best of your knowledge, and that of the Taxpayers, none of the issues involved in this advance income tax ruling request are: (i) in an earlier return of any of the Taxpayers 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 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 expired; or (v) the subject of a ruling previously issued to any of the Taxpayers by the Income Tax Rulings Directorate. ...