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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. ...

You have advised us that to the best of your knowledge and that of the Taxpayers, none of the issues involved in this ruling request are: (i) in an earlier return of the Taxpayers or persons who are related to the Taxpayers; (ii) being considered by a tax services office or taxation centre in connection with a tax return filed previously by any of the Taxpayers or persons who are related to any of the Taxpayers; (iii) under objection by any of the Taxpayers or any person who is related to the any of the Taxpayers; (iv) before the courts; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

In this regard, we acknowledge your written submissions of XXXXXXXXXX made in connection with your request, our numerous telephone conversations with respect thereto XXXXXXXXXX You have advised us that to the best of your knowledge, and that of the Taxpayers, none of the issues contained herein is: (a) in an earlier return of a Taxpayer or a person related to a Taxpayer; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of a Taxpayer or a person related to a Taxpayer; (c) under objection by a Taxpayer or a person related to a Taxpayer; (d) the subject of a ruling previously issued by the Income Tax Rulings Directorate; or (e) before the Courts. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in this ruling request is: (i) in a previously filed tax return of the taxpayers or persons related to the taxpayers; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or persons related to the taxpayers; (iii) under objection by the taxpayers or persons related to the taxpayers; (iv) the subject of a current or completed court process involving the taxpayers or persons related to the taxpayers; or (v) the subject of an advance income ruling previously issued by the Income Tax Rulings Directorate. ...

To the best of your knowledge, and that of the taxpayers named herein, none of the issues involved in this advance income tax ruling request is under objection or appeal or is being considered by any tax services office or taxation centre of Revenue Canada in connection with any income tax return already filed. ...

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: 1. is in an earlier return of the taxpayer or a related person, 2. is being considered by a tax services office or a taxation centre in connection with a previously filed tax return of the taxpayer or a related person, 3. is under objection by the taxpayer or related person, 4. is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired, or 5. is the subject of a ruling previously issued by the Directorate. ...

To the best of your knowledge, and that of the taxpayer involved, none of the issues contained herein is: (a) dealt with in an earlier return of the taxpayer or a related person; (b) 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; (c) under objection by the taxpayer or a related person; (d) the subject of a ruling previously issued by the Income Tax Rulings Directorate; or (e) before the courts. ...

To the best of your knowledge, and that of the taxpayers named herein, none of the issues involved in this advance income tax ruling request is under objection or appeal or is being considered by any tax services office or taxation centre of Revenue Canada in connection with any income tax return already filed. ...

We understand that, to the best of your knowledge and that of the Taxpayers, none of the proposed transactions and/or issues involved in this ruling are the same as, or substantially similar to, transactions and/or issues that are: a. in a previously filed tax return of the Taxpayers or person related to the Taxpayers; b. being considered by the CRA in connection with a previously filed tax return of the Taxpayers or a person related to the Taxpayers; c. under objection by the Taxpayers or a person related to the Taxpayers; d. before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; or e. the subject of an advance income tax ruling previously issued by the Income Tax Rulings Directorate of the CRA in connection with the Taxpayers or a person related to the Taxpayers. ...

You have advised that to the best of the knowledge of the responsible officers of each of the Applicants and yourselves, none of the issues involved in this Ruling: is in an earlier tax return of any of the Applicants or a related person; (i) is being considered by a tax services office or taxation centre in connection with a previously filed tax return or of any of the Applicants or a related person; (ii) is under objection by any of the Applicants or a related person; (iii) is before the courts; or (iv) is the subject of a ruling previously issued by the Income Tax Rulings Directorate of Canada Customs and Revenue Agency ("CCRA") You have advised that to the best of the knowledge of the responsible officers of each of the Applicants, the Proposed Transactions will not have any impact on existing outstanding tax liabilities, if any, of any of the Applicants. ...