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

The ABCHoldco Common Shares that the AsHoldcos, the BsHoldcos and the CsHoldcos currently own were acquired by them in a somersault transaction in 1996, which was the subject of a ruling dated XXXXXXXXXX, 1996 (document # 9626043) ("1996 Ruling"). ...

Buyer GP has a XXXXXXXXXX % interest in Buyer LP. 11. Buyer Holdings operates as a holding company and its principal assets are the shares of the capital stock of Buyerco and advances made to Buyerco. ...

In connection with the dissolution: i) All of the remaining property of Subco 1 (including the Newco Common Shares, the Parent-Subco 1 Note and the Parent Preferred Shares) will be distributed to, and all of the remaining liabilities of Subco 1 will be discharged or assumed by, Parent; ii) The Parent Preferred Shares distributed to Parent on the winding-up will be cancelled by Parent; iii) The Parent – Subco 1 Note will be settled as a result of the winding-up of Subco 1 as a matter of law, due to the merger of rights of debtor and creditor. ...

The total purchase price of the Purchased Assets was allocated as follows: Land $ XXXXXXXXXX Land Improvements XXXXXXXXXX Buildings XXXXXXXXXX XXXXXXXXXX Equipment and Machinery XXXXXXXXXX $XXXXXXXXXX The Trust funded the purchase of the Purchased Assets by issuing interest bearing Notes to various public financial institutions and by issuing Trust Certificates to XXXXXXXXXX. ...

Corporations owned by Child 1 and Child 2 will become beneficiaries of the Family Trust in case Child 1 or Child 2 is a non-resident at the time a distribution would otherwise have been made to that child and which would have been subject to the proposed rule in the Notice of Ways & Means Motion of October 2, 1996 to the effect that property so distributed is deemed to have been disposed of at fair market value. ...

. * As defined in draft section 143.2. The opinions expressed above are provided in accordance with paragraph 22 of Information Circular 70-6R2. ...

The terms of the Holdco I Note will provide that a portion of the interest payable on the note (approximately XXXXXXXXXX %) will be paid in the taxation year the expense is incurred and the unpaid portion will be paid prior to the end of the second taxation year following the taxation year in which the expense was incurred. 19. ...

XXXXXXXXXX will sell, at fair market value, to Subco XXXXXXXXXX % of its cash and near-cash property and investment property. ...

The Exercise Price will be approximately XXXXXXXXXX % of the market price (on the XXXXXXXXXX Stock Exchange) of the CCo Stock (XXXXXXXXXX) on the date on which the offering of the Units is priced. ...