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To the best of your knowledge, and that of the above-noted taxpayers, none of the issues involved in this advance income tax ruling request are: (i) in an earlier return of any of the above-noted taxpayers or a related person; (ii) being considered by a Tax Services Office or a Taxation Centre in connection with a previously-filed tax return of any of the above-noted taxpayers or a related person; (iii) under objection by any of the above-noted 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 to any of the above-noted taxpayers by the Income Tax Rulings Directorate. ...

To the best of your knowledge, and that of the Taxpayers, none of the issues involved in this advance income tax ruling are: (i) in an earlier return of any of the Taxpayers or a related person; (ii) being considered by a Tax Services Office or a 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, 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 to any of the Taxpayers by the Income Tax Rulings Directorate. ...

We also acknowledge the additional information provided in your subsequent correspondence dated XXXXXXXXXX We understand that, to the best of your knowledge and that of the taxpayers, none of the issues involved in the ruling request is: a) in an earlier tax return of the taxpayers or of any related persons; b) being considered by a tax services office or a tax centre in connection with a tax return already filed by the taxpayers or by any related persons; c) under objection by the taxpayers or any related persons; d) before the courts or, e) the subject of a ruling previously issued by the Directorate to the taxpayers or to any related persons. ...

We understand that, to the best of your knowledge and that of the Taxpayers, none of the issues involved in the ruling is: (i) 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 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, none of the issues involved in the ruling request is: i. in an earlier return of any of the Taxpayers 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 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. except as set out in Ruling 2015-060144, the subject of a ruling previously issued by the Directorate to any of the Taxpayers or a related person. ...

To the best of your knowledge, and that of the Corporate Group, any Member or any Participant, none of the issues involved in this Ruling are: (i) in an earlier tax return of any member of the Corporate Group, a Member or a Participant or any person related to a member of the Corporate Group, a Member or a Participant other than with respect to the operation of the deferred compensation plans as they presently exist; (ii) being or have been considered by a tax services office or tax centre in connection with a previously filed tax return of a member of the Corporate Group, a Member, a Participant or any person related to a member of the Corporate Group, a Member or a Participant; (iii) under objection by a member of the Corporate Group, a Member, a Participant or any person related to a member of the Corporate Group a member or a Participant; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; nor (v) the subject of a ruling previously issued by the Directorate to a member of the Corporate Group, a Member, a Participant or any person related to a member of the Corporate Group, a Member or a Participant other than as described in 8 of the above facts. ...

We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in 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 Taxation Center 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; or (iv) is 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 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; or (iv) is 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 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. ...

To the best of your knowledge and that of the Taxpayers, none of the issues involved in the ruling request is: i. in an earlier return of any of the Taxpayers 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 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 Directorate to any of the Taxpayers or a related person. ...