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These rulings are provided subject to the limitations and qualifications set out in Information Circular 70-6R4 issued by the Canada Customs & Revenue Agency on January 29, 2001 and are binding upon the Agency provided that the proposed transactions are completed on or before XXXXXXXXXX. ...

Our understanding of the relevant definitions, the facts, proposed transactions and the purpose of the proposed transactions is as follows: Definitions "A Co" means XXXXXXXXXX as described more fully in paragraph XXXXXXXXXX hereof; "Act" means the Income Tax Act (Canada), and unless otherwise stated, every reference herein to a part, section, subsection, paragraph or subparagraph is a reference to the relevant provision of the Act; "arm's length" has the meaning assigned by section 251; "B Co Companies" means XXXXXXXXXX; "C Co" means XXXXXXXXXX as described more fully in paragraph XXXXXXXXXX hereof; XXXXXXXXXX; "capital property" has the meaning assigned by section 54; "CCRA" means Canada Customs and Revenue Agency; XXXXXXXXXX; "D Co" means a trust established in XXXXXXXXXX pursuant to the laws of XXXXXXXXXX as described more fully in paragraph XXXXXXXXXX; "D Co XXXXXXXXXX" mean XXXXXXXXXX units of beneficial interest in the D Co, XXXXXXXXXX; "D Co XXXXXXXXXX Ruling" means the advance income tax ruling XXXXXXXXXX issued by the CCRA on XXXXXXXXXX; "D Co XXXXXXXXXX Securities" mean D Co XXXXXXXXXX Securities, XXXXXXXXXX, as described in paragraph XXXXXXXXXX hereof; "D Co XXXXXXXXXX Securities" mean D Co XXXXXXXXXX Securities, XXXXXXXXXX, as described more fully in paragraphs XXXXXXXXXX and following hereof; "D Co XXXXXXXXXX " means XXXXXXXXXX as described more fully in paragraph XXXXXXXXXX hereof; "Debenture Redemption Price" has the meaning set out in paragraph 39 hereof; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; "E Co" means XXXXXXXXXX as described more fully in paragraph XXXXXXXXXX hereof; XXXXXXXXXX; XXXXXXXXXX; "E Co XXXXXXXXXX" has the meaning set out in paragraph XXXXXXXXXX hereof; XXXXXXXXXX; XXXXXXXXXX; "F Co" means XXXXXXXXXX as described more fully in paragraph XXXXXXXXXX hereof; XXXXXXXXXX; "G Co" means XXXXXXXXXX as described more fully in paragraph XXXXXXXXXX hereof; XXXXXXXXXX; XXXXXXXXXX; "H Co" means XXXXXXXXXX as described more fully in paragraph XXXXXXXXXX hereof; "I Co" means XXXXXXXXXX as described more fully in paragraph XXXXXXXXXX hereof; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; "prescribed stock exchange in Canada" has the meaning assigned by section 3200 of the Regulations; "principal amount" has the meaning assigned by subsection 248(1); "Proposed Transactions" means the transactions described in paragraphs 26 to 56 hereof; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; "Regulations" means the Income Tax Regulations promulgated under the Act; XXXXXXXXXX; "subsidiary controlled corporation" has the meaning assigned by subsection 248(1); "subsidiary wholly-owned corporation" has the meaning assigned by subsection 248(1); XXXXXXXXXX; XXXXXXXXXX; "taxable Canadian corporation" has the meaning assigned by subsection 89(1); "taxable dividend" has the meaning assigned by subsection 89(1); XXXXXXXXXX; XXXXXXXXXX; Facts 1. ...

CAVEAT These rulings are provided subject to the general limitations and qualifications set out in Information Circular 70-6R5 issued by the Canada Customs & Revenue Agency (the "Agency") on May 17, 2002, and are binding provided that the proposed transactions are completed on or before XXXXXXXXXX. ...

The minimum amount which can be deferred is ten percent (10%) and the maximum is thirty three and one third percent (33 1/3 %). ...

To the best of your knowledge, and that of the taxpayer involved, none of the issues contained herein is: (i) dealt with 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) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ...

. \ XXXXXXXXXX 992307 Attention: XXXXXXXXXX XXXXXXXXXX, 1999 Dear Sirs: Re: Advance Income Tax Ruling XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX, in which you requested an advance income tax ruling on behalf of the above noted taxpayers in respect of the income tax consequences arising out of the proposed transactions described below. ...

Y will be equal to or approximate the amount determined by the formula (A x B/C) + D as found in subparagraph (b)(iii) of the definition of "permitted exchange" in subsection 55(1). ...

Yours truly, for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

Bco owns XXXXXXXXXX % of the shares of a LLC formed in the U.S. which, in turn, owns shares of three LCCs, which own directly properties located in the U.S.. ...

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. ...