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You have advised that to the best of your knowledge, and that of the responsible officers of each of the taxpayers, none of the issues involved in this Ruling is: (i) in an earlier return of the taxpayers or any related person; (ii) being considered by a tax services office ("TSO") or taxation centre ("TC") in connection with a previously filed tax return by the taxpayers or any related person; (iii) under objection by the taxpayers or any 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 any related person. ...

To the best of your knowledge and that of the taxpayer involved, none of the issues contained in this ruling request are: (i) dealt with in an earlier return of the taxpayer or a related person; (ii) being considered by a tax services office or taxation centre of the Canada Revenue Agency ("CRA") 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) subject to a ruling previously issued by the Income Tax Rulings Directorate to the taxpayer 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 involved none of the issues involved in the requested ruling is: (i) dealt with in an earlier return of ACO or a related person; (ii) being considered by any tax services office or taxation centre in connection with a tax return already filed; (iii) under objection by ACO or by a related person; (iv) the subject of a previously issued ruling by the Income Tax Rulings Directorate of the CRA to ACO or a related party; nor (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

You advise that to the best of your knowledge and that of the taxpayers referred to above, none of the issues involved in the ruling request: i. is in an earlier return of the taxpayers or a related person; ii. is being considered by a tax services office or tax 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; or v. is the subject of a ruling previously issued to the taxpayers by the Directorate. ...

To the best of your knowledge and that of the Taxpayers, none of the issues involved in this ruling are: (i) 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) before the courts; 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 with this request: (i) is involved in an earlier return of the taxpayer or a related person; (ii) is being considered by a tax services office or a taxation centre in connection with a tax return already filed by the taxpayer or a related person; (iii) is under objection; or (iv) is before the courts or, if a judgement has been issued, the time limit for appeal has not 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 Parent, X Co, Newco 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 Parent, X Co, Newco or a related person; (iii) under objection by Parent, X Co, Newco 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. ...

To the best of your knowledge and that of the taxpayer involved, none of the issues contained in this ruling request are: (i) dealt with in an earlier return of the taxpayer or a related person; (ii) being considered by a tax services office or taxation centre of the Canada Revenue Agency ("CRA") 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) subject to a ruling previously issued by the Income Tax Rulings Directorate to the taxpayer 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 taxpayers involved, none of the issues contained in this ruling request herein are: (i) dealt with in an earlier return of Profitco, Lossco, 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 Profitco, Lossco or a related person; (iii) under objection by Profitco, Lossco or a related person; (iv) the subject of a previous ruling issued by the Income Tax Rulings Directorate to Profitco, Lossco 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 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 the 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; nor (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired. ...