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Ruling # 2005-011948, dated XXXXXXXXXX, 2005, was obtained in respect of the formation of Partnership in XXXXXXXXXX. 15. ...

Advance income tax ruling # 2005-011948, dated XXXXXXXXXX, 2005, was obtained from the CRA in respect of the formation of Partnership in XXXXXXXXXX. 15. ...

Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

The authorized share capital of Dco consists of an unlimited number of XXXXXXXXXX % non-cumulative, redeemable preference shares and an unlimited number of common shares. ...

New Subco 1's authorized capital consists of an unlimited number of voting and fully participating common shares; "Non-Resident" means: (i) a person (within the meaning of subsection 248(1) but, for greater certainty, not including a partnership) who is not resident in Canada for the purposes of the Act; or (ii) a partnership that is not a "Canadian partnership" as defined in subsection 248(1); "Other Shareholders" means XXXXXXXXXX which directly or indirectly owned approximately XXXXXXXXXX % of the total Target Shares, XXXXXXXXXX. which directly or indirectly owned approximately XXXXXXXXXX% of the total Target Shares and Management who never owned directly or indirectly more than approximately XXXXXXXXXX% of the total Target Shares from XXXXXXXXXX until the Effective Time. ...

Yours truly, XXXXXXXXXX Section Manager For Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

The issued and outstanding shares of DC are owned as follows: Shareholder Common Shares Preferred Shares % of Class Individual1 XXXXXXXX XXXXXXXX XXXXXXXX Holdco1 XXXXXXXX XXXXXXXX XXXXXXXX Individual2 XXXXXXXX XXXXXXXX XXXXXXXX Holdco2 XXXXXXXX XXXXXXXX XXXXXXXX Individual3 XXXXXXXX XXXXXXXX XXXXXXXX Holdco3 XXXXXXXX XXXXXXXX XXXXXXXX Individual4 XXXXXXXX XXXXXXXX XXXXXXXX Holdco4 XXXXXXXX XXXXXXXX XXXXXXXX Each of the shareholders of DC holds its shares of DC as capital property. ...

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

The members of the Partnership are Opco (as to an approximate XXXXXXXXXX% interest), Sub 1 (as to an approximate XXXXXXXXXX % interest), Sub 3 (as to an approximate XXXXXXXXXX% interest) and Sub 2 (as to an approximate XXXXXXXXXX% interest). ...

To date XXXXXXXXXX Class C Shares owned by Sibling2 have been transferred to Holdco and redeemed by DC pursuant to the Class C Redemption Agreement as follows: DC's Taxation Year # of Class C Shares Redeemed XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Subtotal XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Total XXXXXXXXXX None of the above-described redemptions of Class C Shares have taken place in contemplation of, or in connection with, the Proposed Transactions. ...