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To the best of your knowledge, and that of the parties to this ruling, none of the issues contained in this advance income tax ruling is being considered by a Tax Services Office and/or a Taxation Centre in connection with an income tax return previously filed and none of the issues contained herein is under objection or appeal. ...

The XXXXXXXXXX proposes to elect to receive Preferred Shares in the amount of at least $XXXXXXXXXX has represented that none of the main purposes of any proposed acquisition of Preferred Shares is to avoid any limitation on the deductibility of any non-capital or net capital losses of XXXXXXXXXX. 19.To the best of the knowledge of the taxpayers involved, none of the issues involved in the requested rulings is being considered by a taxation service office or a taxation centre in connection with a tax return already filed and none of the issues is under objection or appeal. ...

We understand that, to the best of your knowledge, and that of the taxpayers on whose behalf this ruling is requested, none of the issues contained in this advance income tax ruling are: i) contained in earlier returns of the taxpayers or related persons; ii) being considered by a tax service office and/or a tax centre in connection with a tax return previously filed by the taxpayers or related persons; iii) under objection by the taxpayers or related persons; iv) before the courts; or v) the subject of a ruling previously issued by the Directorate to the taxpayers or related persons. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein 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; or (iv) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ...

You have advised us that to the best of your knowledge and that of the taxpayers involved 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 not 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 with this 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 a 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 judgement 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. ...

being considered by a tax services office or by a taxation centre in connection with a previously filed tax return of the Corporation 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 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; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not 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 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; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...

To the best of your knowledge, and that of the general partner of the Partnership, none of the issues contained in this ruling request is: (i) dealt with in an earlier return of any prospective member of the Partnership 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 prospective member of the Partnership or a related person; (iii) under objection or appeal by any prospective member of the Partnership or a related person; or (iv) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has expired. ...