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Comment You have requested that we provide a ruling on possible future transactions (re: " The applicability of Section 110.6(7) of the Act to the situation should an eventual sale of shares occur in future. ...

The acquisition was funded in part by bank borrowing subsequently acquired by NRO # 3 (i.e., NRO Loan 3). ...

XXXXXXXXXX 2016-068076 XXXXXXXXXX, 2017 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request XXXXXXXXXX – Business Number: XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX and your subsequent correspondence in which you requested an advance income tax ruling on behalf of the above-noted taxpayer (the “Corporation”). ...

Reasons: Same as- 2002-0133063; 2001-0102663; see also 2002-0152593, 2001-0080983 & E9915403 XXXXXXXXXX 2002-016997 XXXXXXXXXX, 2003 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX We are writing in reply to your letter dated XXXXXXXXXX requesting an advance income tax ruling on behalf of the above taxpayers. ...

DEFINITIONS In this letter, the following terms have the meanings specified: (a) "ACB" means "adjusted cost base" and has the meaning assigned by section 54; (b) "Act" means the Income Tax Act, R.S.C. 1985 (5th Suppl.) c.1, as amended to the date hereof, and unless otherwise stated, a reference herein to a part, section, subsection, paragraph or subparagraph is a reference to the relevant provision of the Act and the regulations thereunder are referred to as the "Regulations"; (c) "affiliated persons" has the meaning assigned by subsection 251.1(1); (d) "agreed amount" means the amount agreed on in respect of a property in an election filed pursuant to subsection 85(1); (e) "Canco" means XXXXXXXXXX; (f) "CCRA" means the Canada Customs and Revenue Agency; (g) "Corporate Act" means the Companies Act of XXXXXXXXXX \; (h) "capital cost allowance" refers to the deduction allowed under paragraph 20(1)(a); (i) "dividend rental arrangement" has the meaning assigned by subsection 248(1); (j) "FMV" means fair market value; (k) "Lossco" means XXXXXXXXXX. ...

Yours truly, XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch ...

The aggregate fair market value of the capital notes will at all times not exceed XXXXXXXXXX % of the aggregate fair market value of all shares in the capital stock and all debt obligations of XXXXXXXXXX then outstanding. ...

The XXXXXXXXXX ("XCo"), which owned approximately XXXXXXXXXX % of the outstanding Target Shares (approximately XXXXXXXXXX% on a fully diluted basis) irrevocably agreed to deposit all of the Target Shares it owned to Offeror. ...

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

XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...