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The aggregate FMV, immediately before the transfer of property by Canadian DC to Canadian TC described in Paragraph 120, of the common shares of the capital stock of New DC owned by Forco 23 will be equal to or approximate the amount determined by the formula, on the assumption that Forco 23 is the participant, Canadian DC is the distributing corporation and New DC is the acquiror, (A × B/C) + D as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1). 117. ... The aggregate FMV, immediately before the transfer of property by New DC to New TC described in Paragraph 135, of the shares of New DC owned by Forco 14 will be equal to or approximate the amount determined by the formula, on the assumption that Forco 14 is the participant, New DC is the distributing corporation and New Global Holdco is the acquiror, (A × B/C) + D as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1). 135. ...

As minor & unborn children were involved the value of the contingent capital interests were determined & set aside in a separate trust. ...

For the purpose of this ruling letter, the above related entities will collectively be referred to as the "XXXXXXXXXX Group". 7.The taxation services office ("TSO"), the taxation centre ("TC"), and the Revenue Canada account number ("RCT #") of the various members of the XXXXXXXXXX Group and XXXXXXXXXX are as follows: CorporationTSO/TCRCT # XXXXXXXXXX 8.XXXXXXXXXX is a taxable Canadian corporation and a public corporation, as those expressions are defined in subsection 89(1), whose shares are listed for trading on the XXXXXXXXXX. ...

" means XXXXXXXXXX; (x.2) "Q1 XXXXXXXXXX " means the new XXXXXXXXXX company to be incorporated and subsequently amalgamated with Q1 Ltd.; (y.2) "Q2 Ltd. ... " means XXXXXXXXXX, a wholly owned subsidiary of DC2; (c.3) "Q3 Amalco" means the amalgamated XXXXXXXXXX company formed on the amalgamation of Q3 Ltd. and Q3XXXXXXXXXX; (d.3) "Q3 XXXXXXXXXX " means the new XXXXXXXXXX company to be incorporated and subsequently amalgamated with Q3 Ltd.; (e.3) "Q4 Ltd. ... Immediately after the share exchanges described herein, the FMV of the shares of TC2 owned by each holder of TC2 shares 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). ...

For each calendar year in which an Emitter has not reduced its GHG emissions by the required amount, the Emitter will be required to compute and pay to the Fund a CCP equal to the positive amount calculated in accordance with the following formula: CCP = XXXXXXXXXX where: A is the Emitter's actual GHG emissions level for the year; P is the Emitter's GHG emissions level for the year as prescribed in the Draft Climate Regulations after the application of the reductions required by the Draft Climate Regulations; O is any offset credit utilized by the Emitter for the year towards achievement of its required reductions; PC is the number of tonnes of CO2e of Performance Credits utilized by the Emitter for the year towards the achievement of its required reductions; PCI is the number of tonnes of CO2e allocated to the Emitter by the Minister as a result of investment by that Emitter in a Pre-Certified Investment that the Emitter is able to include during the year towards the achievement of its required reductions; REA is the number of tonnes of CO2e allocated to the Emitter by the Minister with respect to recognition for early action that the Emitter is able to include in the year towards the achievement of its required reductions; OC is the amount of other tonnes of CO2e that the Minister permits the Emitter to deduct; and C is the XXXXXXXXXX as prescribed in the Draft Climate Regulations. 51. ... An Emitter for the purpose of the Climate Act will include industrial facilities as follows: (a) electricity generation; (b) petroleum refining facilities; (c) oil sands facilities; (d) pulp and paper facilities (e) steel production facilities; (f) natural gas pipelines – facility based with a minimum of 50 kt CO2e per year; (g) upstream oil and gas facilities – facility based with a minimum threshold of 50 kt CO2e per year; (h) fertilizer plants – facility based with a minimum threshold of 50 kt CO2e per year; (i) chemical plants- facility based with a minimum threshold of 50 kt CO2e per year; (j) potash mines- facility based with a minimum threshold of 100 kt CO2e per year; (k) coal carbonizing plants- facility based with a minimum threshold of 50 kt CO2e per year; (l) Ethanol plants, biodiesel facilities or canola crushing plants. ...

XXXXXXXXXX 2013-050729 XXXXXXXXXX, 2013 Dear XXXXXXXXXX: Re: Amended Advance Income Tax Ruling Request in respect of XXXXXXXXXX (the "Taxpayer") – XXXXXXXXXX This is in response to your correspondence dated XXXXXXXXXX, wherein you requested amendments to our advance income tax ruling 2013-048835 (the "Ruling") issued on XXXXXXXXXX, 2013. ... In respect of the Taxpayer Debenture REIT # 1 shall directly assume the liability as part of the consideration for the transfer of the Taxpayer Property referred to in 37 above, and REIT #1 shall be responsible for payments on the Taxpayer Debenture directly to the Taxpayer Debenture holders. 41. ... Provided that immediately after the Proposed Transactions REIT # 1 shall own all or substantially all of the assets that the Taxpayer previously owned, directly or indirectly, immediately before the Proposed Transactions, the provisions of subsections 15(1), 56(2), 56(4), 69(1), 69(4), 105(1) and 246(1) of the Act will not apply as a result of the Proposed Transactions, in and by themselves. ...

The objects of Corporation G, as set out in its memorandum of association, are: a. to acquire and take over all or any part of the assets and liabilities of the present unincorporated body known as the "XXXXXXXXXX "; b. to promote XXXXXXXXXX and other athletic sports and pastimes; c. to establish, maintain and conduct a XXXXXXXXXX and to afford the members of such club all the usual privileges, advantages, conveniences and accommodations of a club; d. to acquire by purchase, lease or otherwise grounds near XXXXXXXXXX and to lay out and prepare the same for XXXXXXXXXX or other athletic sports or pastimes; e. to buy, hire, prepare, make or provide and maintain and to sell all things required or which may be conveniently used in connection with the XXXXXXXXXX grounds, club-house and other premises of the Company by persons frequenting the same; and f. to buy, prepare, make, supply, sell and deal in all kinds of XXXXXXXXXX and other athletic sports and pastimes; and all kinds of liquors, provisions and refreshments (subject to any laws of the Province of XXXXXXXXXX in that behalf) required or used by the members of such club or other persons frequenting the lands, club-houses or premises of the Company. ... Interest applies at the rate of XXXXXXXXXX % on unpaid calls, though directors are at the liberty to waive payment of that interest in whole or part. 11. ... Interest applied at the rate of XXXXXXXXXX % on unpaid calls, though directors are at liberty to waive payment of that interest in whole or in part. ...

The last such redemption occurred in XXXXXXXXXX 3.The authorized share capital of XXXXXXXXXX is as follows: 1st preferred shares-XXXXXXXXXX authorized-redeemable at $XXXXXXXXXX each, with non-cumulative dividends equal to XXXXXXXXXX% per share-one vote per share 2nd preferred share-XXXXXXXXXX authorized-redeemable at $XXXXXXXXXX per share, non-participating-one vote per share 3rd preferred shares-unlimited number authorized-redeemable at $XXXXXXXXXX per share, with non-cumulative dividends equal to $XXXXXXXXXX per share-non-voting common shares-unlimited number authorized-one vote per share 4.At the present time the issued and outstanding shares of XXXXXXXXXX are as follows and are held equally by XXXXXXXXXX: Class of Shares # Issued PUC XXXXXXXXXX The 1st and 2nd preferred shares have an ACB and fair market value equal to their PUC. ... At its year end on XXXXXXXXXX had a RDTOH balance of approximately $XXXXXXXXXX and an estimated CDA of $XXXXXXXXXX 6.The authorized share capital of XXXXXXXXXX is as follows: first preferred shares-XXXXXXXXXX authorized-$XXXXXXXXXX fixed cumulative cash dividend-non-participating, redeemable at the amount paid thereon-non-voting second preferred shares-unlimited number authorized-XXXXXXXXXX% non-cumulative dividend-non-participating, redeemable at the amount paid thereon-entitled to one vote per share third preferred shares-unlimited number authorized-XXXXXXXXXX% non-cumulative dividend-non-participating, redeemable at the amount paid thereon-entitled to XXXXXXXXXX votes per share fourth preferred shares-unlimited number authorized-XXXXXXXXXX non-cumulative dividend-non-participating, redeemable at the amount paid thereon-non-voting fifth preferred shares-unlimited number authorized- XXXXXXXXXX% non-cumulative dividend-non-participating, redeemable at the amount paid thereon-entitled to one vote per share common shares-unlimited number authorized-participating-entitled to one vote per share 7.At the present time the issued and outstanding shares of XXXXXXXXXX are as follows and are held equally by XXXXXXXXXX: Class of Shares # Issued PUC XXXXXXXXXX The third preferred shares and the fourth preferred shares have a PUC, ACB and fair market value of $XXXXXXXXXX and $XXXXXXXXXX, respectively. ... XXXXXXXXXX has a year end at XXXXXXXXXX and files its T2 returns at the XXXXXXXXXX Taxation Centre under corporate account # XXXXXXXXXX. ...

The book values of the other assets of XXXXXXXXXX on hand, as at XXXXXXXXXX, were as follows: Investment in shares of Subco $ XXXXXXXXXX Note receivable from Subco XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Other receivable XXXXXXXXXX Cash and short-term deposits XXXXXXXXXX Prepaid property taxes and other items XXXXXXXXXX Total $ XXXXXXXXXX The outstanding principal amounts of the liabilities of XXXXXXXXXX, were as follows: Mortgage payable $XXXXXXXXXX Bank debt on rental properties XXXXXXXXXX Advances to affiliated companies, net XXXXXXXXXX of $XXXXXXXXXX due from Newco Trade payables and accrued liabilities XXXXXXXXXX Income taxes payable XXXXXXXXXX Deferred income XXXXXXXXXX $ XXXXXXXXXX The balance of XXXXXXXXXX retained earnings as at XXXXXXXXXX was $XXXXXXXXXX. ...

The term of the Temporary Services Agreement will expire at the earlier of (a) the Operating Partnership acquiring the XXXXXXXXXX Business of the Opco or successor company; and (b) notice being given by the Opco; (xxx) "Trust" or "XXXXXXXXXX " means XXXXXXXXXX, an unincorporated closed-end unit trust that qualifies as a mutual fund trust, established under the laws of the Province of XXXXXXXXXX; (yyy) "Trust Unit" means a trust unit of XXXXXXXXXX, each such unit representing an equal undivided beneficial interest therein; (zzz) "Trustees" means the individuals that act as trustees of XXXXXXXXXX in accordance with and subject to the provisions of the XXXXXXXXXX Declaration of Trust, and which as of the date hereof consist of XXXXXXXXXX Canadian resident individuals, namely XXXXXXXXXX; (aaaa) XXXXXXXXXX; (bbbb) "unit trust" means a trust that qualifies as a unit trust under subsection 108(2); and (cccc) "Unitholder" means a holder of one or more Trust Units. ... In accordance with paragraph 108(2)(b), paragraph 132(6)(b), subsection 132(7) and the relevant terms of the XXXXXXXXXX Declaration of Trust, the Trust qualifies as a mutual fund trust and, specifically, the Trust: (1) limits its undertaking to the investing of its funds in property, and to acquiring, holding, maintaining, improving, leasing and managing real property and interests in real property that is capital property; (2) invests more than XXXXXXXXXX% of its property in Permitted Investments; (3) earns more than XXXXXXXXXX % of its income- computed without regard to subsection 104(6)- from Permitted Investments; (4) does not invest any more than 10% of its property in any combination of bonds, securities or shares of any one Investee; and (5) is not maintained primarily for the benefit of non-resident persons, and non-residents of Canada are collectively beneficial owners of less than XXXXXXXXXX% of the Trust Units. 7. ... Pursuant to the terms of the XXXXXXXXXX Declaration of Trust, the Trust is required to distribute to Unitholders monthly a cash distribution from the Trust in an amount determined by the Trustees that is at least equal, in any one fiscal year of the Trust, to the greater of (i) the taxable income of the Trust, for purposes of the Act, for such fiscal year; and (ii) XXXXXXXXXX % of the Distributable Cash of the Trust for such fiscal year. 10. ...