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We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in the requested rulings is being considered by any tax services office or taxation centre in connection with a tax return already filed, or is under objection or appeal. ...

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; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations 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. ...

You advise that to the best of your knowledge and that of the parties involved, none of the issues involved in this ruling request is being considered by a Tax Services Office or Taxation Centre in connection with any tax return already filed and, further, none of the issues involved is the subject of any notice of objection or is under appeal. ...

We understand that to the best of your knowledge and that of the taxpayers involved none of the issues involved in the requested rulings is being considered by a tax services office or a taxation centre in connection with a tax return already filed, or is under objection or appeal. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues involved contained herein is: (i) in an earlier return of one of the taxpayers or of a person related to them; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of one of the taxpayers or a related person; (iii) under objection by one 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 Directorate. ...

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 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 previous 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 has not expired; or (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 Company, none of the issues involved in the ruling request (i) is in an earlier return of the Company 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 Company or a related person, (iii) is under objection by the Company or a related person, (iv) is before the courts, or (v) is the subject of a ruling, other than the ruling referred to in 11 below, 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 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 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. ...

To the best of your knowledge, and that of the Applicants involved, none of the issues contained herein is: (i) dealt with in an earlier return of one or any the Applicants or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of one or any of the Applicants or a related person; (iii) under objection by one or any of the Applicants or a related person; (iv) is the subject of a ruling previously issued by the Income Tax Rulings Directorate except certain transactions XXXXXXXXXX; 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 taxpayer, none of the issues involved in the 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 (v) the subject of a ruling previously issued by the Directorate to the taxpayer or a related person, except for the 2002 Ruling noted in paragraph 3, below; 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. ...