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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 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 involved in this ruling request is (i) 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, 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-referenced Corporation, none of the issues involved in the ruling request is: (i) in an earlier return of the Corporation or a related person; (ii) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Corporation or a related person; (iii) under objection by the Corporation or a related person; (iv) before the courts; nor, (v) the subject of a ruling previously issued by the Directorate. ...

We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in this Ruling letter: (i) is in an earlier return of the taxpayer 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 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 Income Tax Rulings Directorate. ...

To the best of your knowledge and that of the taxpayer, none of the issues involved in the ruling request is: (i) dealt with in an earlier tax return of the taxpayer or a person (a "specified person") who is a person related to the taxpayer or who is a Participant in the Plan referred to below; (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 specified person; (iii) under objection by the taxpayer or a specified 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 Directorate, other than Ruling 2003-0040931 dated XXXXXXXXXX, Ruling 2007-0246431 dated XXXXXXXXXX, and Ruling 2008-0287641 dated XXXXXXXXXX. ...

We understand that, to the best of your knowledge and that of the taxpayer, 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 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 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 in the Original Ruling or in the Supplemental Ruling Unless otherwise stated, all references to a statute are to the Income Tax Act (Canada), R.S.C. 1985, c.1 (5th Supp.), as amended to the date of this letter, (the "Act"), and all terms and conditions used herein that are defined in the Act have the meaning given in such definition unless otherwise indicated. ...

Also, to the best of your knowledge, and that of Canco1, none of the issues involved in this advance rulings request is: (i) in an earlier return of Canco1 or a related person; (ii) being considered by a Tax Services Office or Taxation Centre in connection with a previously filed tax return of Canco1or a related person; (iii) under objection by Canco1 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 rulings 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 are: (i) dealt with in an earlier return of Lossco, Profitco 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 Lossco, Profitco or a related person; (iii) under objection by Lossco, Profitco, or a related person; (iv) the subject of a ruling previously issued by the Income Tax Directorate to Lossco, Profitco, 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, none of the 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, none of the issues involved in this ruling is: (i) 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 Directorate to the taxpayer or a related person. ...