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XXXXXXXXXX 2021-087667 XXXXXXXXXX, 2021 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request – Transfer between U.S. pension plans XXXXXXXXXX This is in reply to XXXXXXXXXX email of XXXXXXXXXX requesting that we resume our consideration of the request for an advance income tax ruling (“Ruling”) on behalf of the XXXXXXXXXX that was originally submitted in XXXXXXXXXX letter of XXXXXXXXXX. ...

The Fund directly holds all of the outstanding units and notes of XXXXXXXXXX Trust, and indirectly holds limited partnership units of XXXXXXXXXX LP (representing approximately XXXXXXXXXX % of the outstanding limited partnership units of XXXXXXXXXX LP), all of the shares of GP Co (the sole trustee of the Trust, being the general partner of XXXXXXXXXX LP and Holdings LP), and all of the shares of Beneficiary, the sole beneficiary of the Trust. 3. ... However, advances evidenced by the Sub-Loan Note will bear interest at a rate of XXXXXXXXXX % per annum in excess of the interest rates under the New Credit Facility. 30. ...

Partnership will assume the O & M Agreement such that the XXXXXXXXXX Assets will be operated in substantially the same manner a before their transfer to Partnership. 18. ... It is not anticipated that any prospective Debenture Holder will hold more than XXXXXXXXXX % of the units of Income Fund. ...

XXXXXXXXXX prior ruling (file # 972815) re: identical transaction (transaction was not completed). 2. ... On the Redemption Date, ACO will be required to make a cash payment equal to the Redemption Price to those Holders who surrender their Units for redemption. g) If a Fundamental Change of Control (as defined below) of BCO occurs, each Holder will have the right, at the Holder's option, to require ACO to purchase all or any part of the Holder's Units on the date (the "Repurchase Date") that is XXXXXXXXXX days after the date ACO gives notice of the Fundamental Change of Control at a price (the "Repurchase Price") equal to XXXXXXXXXX % of their Principal Amount plus accrued Interest to the Repurchase Date, after which the related Warrants will automatically expire. ...

Note " means the interest-bearing promissory note in the principal amount of USD$XXXXXXXXXX issued by ULC to U.S. ... Yours truly, XXXXXXXXXX Section Manager For Division Director International Section I Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

On XXXXXXXXXX, Eco used part of its excess funds to make an interest free loan of $ XXXXXXXXXX to Cco (the “Cco Loan”). 20. On XXXXXXXXXX, Cco, with the proceeds from the Cco Loan, made an interest free loan of $ XXXXXXXXXX to Aco (the “Aco Loan 2”). ...

., c. 95, as amended; (bb) “Stock Exchange” means the XXXXXXXXXX; (cc) “Sub-Custodian” means XXXXXXXXXX; (dd) “Sub-Custodian’s Parent” means XXXXXXXXXX; (ee) “subsidiary wholly-owned corporation” has the meaning assigned by subsection 248(1) of the Act; (ff) “Tax Treaty” has the meaning assigned by subsection 248(1) of the Act; (gg) XXXXXXXXXX; (hh) “TLCA” means the Trust & Loans Companies Act (S.C. 1991, c. 45); (ii) “Unit(s)” means a unit of account, representing a proportionate undivided co-ownership interest in the assets of the Fund, as tenants in common with the other Unitholders. ... The executive partners own XXXXXXXXXX % of the Investment Manager with the remaining XXXXXXXXXX% owned by investors. ...

After degassing, the emulsion will be cooled through a heat exchanger to approximately XXXXXXXXXX ° C. (iv) Emulsion Treating System: The water content in the bitumen will typically be less than XXXXXXXXXX % as the bitumen leaves the production separation system and is split into two streams that feed the XXXXXXXXXX treaters. ...

All of the authorized Series A Preferred Shares are issued and outstanding and are owned by XXXXXXXXXX ULC. 10) The Series A Preferred Shares have the following attributes: a) redeemable and retractable no sooner than XXXXXXXXXX years after the day following the date of issue for an amount (the "Redemption Amount") equal to $XXXXXXXXXX US in aggregate; b) voting, with a fixed cumulative annually-compounding dividend equal to XXXXXXXXXX % of the Redemption Amount plus any unpaid dividends from all prior years- no dividend may be paid on any other class of shares which would impair US Opco's ability to redeem the Series A Preferred Shares at the Redemption Amount. 11) The ACB of the Series A Preferred Shares is equal to the elected amount that was claimed under a section 85 election in respect of the transfer of XXXXXXXXXX Foreign Affiliates by XXXXXXXXXX ULC to US Opco at the time of the issuance of the shares. ... PROPOSED TRANSACTIONS Sale of Series A Preferred Shares 23) Prior to XXXXXXXXXX,XXXXXXXXXX ULC will sell a minimum of XXXXXXXXXX % of the Series A Preferred Shares of US Opco to US Subco for proceeds of disposition equal to the then fair market value of the shares. ...

Subco is a taxable Canadian corporation, XXXXXXXXXX % of the shares of which were, prior to XXXXXXXXXX, owned by Targetco1. ... The XXXXXXXXXX % of the shares of Subco have, at all times, been owned by a person dealing at arm's length with Targetco1 and Aco. 5. ...