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You have advised that to the best of your knowledge, and that of the individual taxpayers and the responsible officers of Opco and Subco, none of the issues involved in this Ruling is: (i) in an earlier return of any 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 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 by the Income Tax Rulings Directorate. ...

We understand that to the best of your knowledge, and that of the above taxpayer, none of the following 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. ...

We understand that to the best of your knowledge and that of the taxpayer involved, none of the issues involved in this ruling request herein is: (i) in a 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 of the CRA to the taxpayer or a related person. ...

We understand that to the best of your knowledge and that of the taxpayers involved none of the issues involved in this ruling 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 to the taxpayers or a related person by the Income Tax Rulings Directorate; or (v) 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 the ruling request: i. is in an earlier return of a 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 a taxpayer or a related person; iii. is under objection by a 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; and v. is the subject of a ruling previously issued by the Canada Revenue Agency (hereafter, the "CRA"). ...

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 involved in the ruling request: (i) is in an earlier return of a 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 a taxpayer or a related person; (iii) is under objection by a 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; and (v) is the subject of a ruling previously issued by the Directorate. ...

We understand that to the best of your knowledge, and that of the Applicants, none of the issues contained herein: (a) is in an earlier tax return of any of the Applicants or a related person; (b) is being considered by a tax services office or taxation centre in connection with a previously filed tax return of any of the Applicants or a related person; (c) is under objection by any of the Applicants or a related person; (d) is before the Courts or, if a judgment has been issued, the time limit for appeal to a higher Court has expired; or (e) is the subject of an advance income tax ruling previously issued by the Income Tax Rulings Directorate in favour of the Applicants. ...

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

You have advised us that to the best of your knowledge and that of the responsible officers of each of the Applicants, none of the issues involved in this Ruling: (i) is in an earlier tax return of any of the Applicants 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 any of the Applicants or a related person; (ii) is under objection by any of the Applicants or a related person; (iii) is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired; or (iv) is the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...