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We understand that, to the best of your knowledge and that of the taxpayer, none of the issues contained in the ruling requested herein is: (a) dealt with in an earlier income tax return of A Co or a related person, (b) being considered by a Tax Services Office or a Taxation Centre in connection with a tax return already filed by A Co or a related person, (c) under objection by A Co or a related person, (d) before the Courts, or if a judgement has been issued, the time limit for appeal to a higher court has expired, or (e) the subject of a previous ruling issued by the Income Tax Rulings Directorate of the CRA. ...

We understand that, to the best of your knowledge and that of the taxpayer involved, 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 Center 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 Directorate. ...

Other than that ruling, to the best of your knowledge and that of the taxpayer, none of the issues in this ruling request is: (i) involved 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 (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 contained in this ruling request herein is: (a) dealt with in an earlier return of A Co, B Co, C Co or a related person; (b) being considered by a tax services office or a taxation centre in connection with a tax return already filed by A Co, B Co, C Co or a related person; (c) under objection by A Co, B Co, C Co 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 previous ruling issued by the Income Tax Rulings Directorate of 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 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; 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 taxpayer involved, none of the issues contained herein: (i) is in an earlier tax 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 judgement has been issued, the time limit for appeal to a higher court has not expired; or (v) is the subject of an advance income tax ruling previously issued by the Income Tax Rulings Directorate. ...

We understand that, to the best of your knowledge, none of the issues involved in the 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 or appeal 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, and (v) is the subject of a ruling previously issued by the Canada Revenue Agency. ...

We acknowledge the additional information we received with your electronic messages of XXXXXXXXXX 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 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) subject to a ruling previously issued 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 expired. ...

To the best of your knowledge and that of the taxpayers, none of the issues in this ruling request is: (i) an issue in an earlier return of any 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 (v) except as disclosed in Paragraph 15 of this letter, 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 taxpayers, 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 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, or (v) is the subject of a ruling previously issued by this Directorate. ...