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Nothing in the Plan shall be considered as creating a trust or creating any fiduciary relationship. ... To the best of your knowledge and that of the Parent, the Corporation and the Employee, none of the issues involved in this ruling are: (a) in an earlier return of the Corporation or the Employee, or any person related to the Corporation, the Employee or a Participant; (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Corporation, the Employee or a Participant, or any person related to the Corporation, the Employee or a Participant; (c) under objection by the Corporation, the Employee, a Participant, or any person related to the Corporation, the Employee or a Participant; (d) before the courts; nor (e) the subject of an income tax ruling previously issued by CRA to the Corporation, the Employer or a Participant except as identified in 9 above. ...

You have advised us that to the best of your knowledge and that of the taxpayer involved none of the issues involved in this ruling request are: (i) in an earlier return of the taxpayer 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 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. ... For greater certainty, any tax accounts, such as the balance of any RDTOH or CDA of DC, will not be considered to be property of DC for purposes of the classification described in this Paragraph. 28. ...

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 request are: (i) in an earlier return 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. ... For greater certainty, the Proposed Transactions, in and by themselves, will not be considered to result in any disposition or increase in interest described in subparagraph 55(3)(a)(i) to (v). ...

You have advised that, to the best of your knowledge and that of the taxpayers, none of the issues involved in the ruling request is: (i) in previously filed tax returns of the taxpayers or a related person; (ii) being considered by a tax services office or a tax centre in connection with previously filed tax returns of the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) the subject of a current or completed court process involving any of the taxpayers or a related person; or (v) the subject of a ruling previously considered by the Directorate. ...

You advise that to the best of your knowledge and that of XXXXXXXXXX, none of the issues involved in the ruling request has been considered by a tax services office or a taxation centre in connection with a tax return already filed, and none of the issues involved in the ruling request is the subject of a notice of objection or is under appeal. ... Q.Provided the Original Loan arose from one or more loans made by the DPS Lenders in the course of their money lending business, the Original Loan reacquired from Newco by the DPS Lenders as described at paragraph 93 above will be considered to have been acquired by the DPS Lenders in the ordinary course of their insurance business for the purposes of paragraph 20(1)(1) and 20(1)(p) of the Act. ...

You have advised that to the best of your knowledge and that of all the taxpayers involved, none of the issues raised in this letter are being considered by any Tax Services Office and/or Taxation Centre in connection with any tax return already filed, nor are any of these issues under objection or appeal. ... Provided the Total XXXXXXXXXX Debt arose from one or more loans made by XXXXXXXXXX in the course of its money lending business, all or any portion of the Total XXXXXXXXXX Debt reacquired by XXXXXXXXXX will be considered to have been acquired by XXXXXXXXXX in the ordinary course of its business of lending money for the purposes of paragraphs 20(1)(1) and 20(1)(p) of the Act. ...

You have advised that, to the best of your knowledge and that of the taxpayers, none of the issues involved in the ruling request is: (i) in previously filed tax returns of the taxpayers or a related person; (ii) being considered by a tax services office or a tax centre in connection with previously filed tax returns of the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) the subject of a current or completed court process involving any of the taxpayers or a related person; or (v) the subject of a ruling previously considered by the Directorate, other than Ruling XXXXXXXXXX issued to you on XXXXXXXXXX in respect of the same taxpayers. ...

We understand that, to the best of your knowledge and that of the XXXXXXXXXX (collectively the "Subsidiaries"), none of the issues in the ruling request is: (a) in an earlier return of the Company, any of the Subsidiaries or a person related to the Company or any of the Subsidiaries, (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Company, any of the Subsidiaries, or a person related to the Company or any of the Subsidiaries, (c) under objection by the Company, any of the Subsidiaries, or a person related to the Company or any of the Subsidiaries, (d) before the courts, or (e) the subject of a ruling previously issued by the Directorate to the Company, any of the Subsidiaries or a person related to the Company or any of the Subsidiaries. ... No benefit will be considered to have been conferred by an Employer on a Final Employer under subsection 15(1) of the Act or under any other provision of the Act by reason only of the Employer making the payment of the reimbursement to the Final Employer described in 13(k) above. ...

You are advised that, to the best of the knowledge of your clients, none of the issues described herein, as they apply specifically to such respective parties, is: (a) in an earlier return; (b) being considered by a tax services office or taxation centre in connection with any tax return previously filed; (c) the subject of any notice of objection or is under appeal; or (d) the subject of a previously issued ruling. ... Any tax accounts such as any non-capital loss, net capital loss, the balance of any RDTOH or capital dividend account will not be considered property for this purpose. 32. ...

To the best of the knowledge of the responsible officers of the existing taxpayer and yourselves, none of the issues involved in this Ruling: (a) is in an earlier tax return of the existing taxpayer 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 the existing taxpayer or a related person; (c) is under objection by the existing taxpayer or a related person; (d) is before the courts; or (e) is the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... Control, for purposes of the Act, of C will not be considered to be have been acquired by a person or group of persons by reason only of the Proposed Transactions. ...