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Shareholders holding not less than XXXXXXXXXX % of the issued voting shares of A Co are entitled to requisition a special meeting of shareholders. ... B Co's Interest in A Co will be no more than XXXXXXXXXX % of the total shareholders' Interests in A Co. ... As such, at any meeting of the board of directors of A Co, B Co would, if its Interest entitled it to appoint XXXXXXXXXX directors, have a minimum of XXXXXXXXXX % (i.e., XXXXXXXXXX of XXXXXXXXXX directors present) and a maximum of XXXXXXXXXX % of the votes (i.e., XXXXXXXXXX of XXXXXXXXXX directors present). 19. ...

The consolidated financial statements of Parent for its fiscal year ended XXXXXXXXXX indicate that Parent and its accounting consolidated group had: * total assets of approximately XXXXXXXXXX$XXXXXXXXXX; * total liabilities of approximately XXXXXXXXXX$XXXXXXXXXX; and * total equity of approximately XXXXXXXXXX$XXXXXXXXXX. 4. ... The expected interest deductions, taxable income and carry back of non-capital losses of Profitco as a result of the transactions that are the subject matter of the XXXXXXXXXX, the XXXXXXXXXX and the Proposed Transactions are as follows (all amounts are in $ XXXXXXXXXX): Taxation year Taxable Interest Interest Interest Carry back ending Income or deduction deduction deductions- of non- Loss XXXXX XXXXX Proposed capital Transactions Losses To prior Years XXXXXXXXXX 32. ...

The expected interest deductions, taxable income and carry back of non-capital losses of Profitco 1 as a result of the Proposed Transactions are as follows (all amounts are in $ XXXXXXXXXX): Taxable income/(Loss) before the Proposed Transactions: XXXXXXXXXX Interest deductions – Proposed Transactions: XXXXXXXXXX Carry back of non capital losses to prior taxation years: XXXXXXXXXX 31. The estimated tax refund of federal and provincial income taxes to Profitco 1 as a result of the Proposed Transactions is as follows (all amounts are in $ XXXXXXXXXX): Estimated tax refund of federal income taxes: XXXXXXXXXX Estimated tax refund of provincial income taxes: XXXXXXXXXX 32. The expected interest deductions, taxable income and carry back of non-capital losses of Profitco 2 as a result of the Proposed Transactions are as follows (all amounts are in $ XXXXXXXXXX): Taxable income/(Loss) before the Proposed Transactions: XXXXXXXXXX Interest deductions – Proposed Transactions: XXXXXXXXXX Carry back of non capital losses to prior taxation years: XXXXXXXXXX 33. ...

Paragraph 38 of the Original Ruling is amended by replacing the words "will be" with the words " have been" after Dco and before the words "…wound-up into Bco…" in the first sentence and replacing the words "will distribute" with "have distributed" after Dco and before the words "…all of their respective properties…" and replacing the words "will assume" with "has assumed" after Bco and before the words "…all of the liabilities…" in the second sentence. 9. Paragraph 45(d) is amended to replace the number "XXXXXXXXXX" with "XXXXXXXXXX" after the words "… on the basis…" and before the words "…Existing Common Shares…". 10. ... Paragraph 45(h) is amended to replace the numbers "XXXXXXXXXX" with "XXXXXXXXXX" before the words "…New Aco Common Shares…" and after the words "…their pro-rata share of …" and replace the number "XXXXXXXXXX" with "XXXXXXXXXX" before the words "…cashless warrants…" and before the words "…New Aco Common Shares and…". ...

As requested, the Ruling is amended as follows: 1. paragraph (aa) "XXXXXXXXXX Event" of the Definitions is deleted in its entirety and replaced with the following: "XXXXXXXXXX Event" means XXXXXXXXXX. 2. paragraph (gg) of the Definitions is amended such that the word "XXXXXXXXXX " is replaced with XXXXXXXXXX. 3. paragraph 11 is amended to restate the words "...Event of Default... ... ". 4. paragraph 13 is amended to delete the words "... that is not an... ... " is deleted and replaced with the words "... XXXXXXXXXX...". 5. paragraph 14 is amended to delete the words "...Interest Reset Date... ...

Definition (m) "Entity C Subco" is amended to change the word "XXXXXXXXXX " to "XXXXXXXXXX. ... Definition (x) " Main Agreement Work B" is amended to add the words "under the Main Agreement" after the word "Project". 8. ... Paragraph 18 is amended to delete the words "... Such new limited partners... ...

RULING Provided that the above statements together with the statements of facts, purposes of proposed transactions and the proposed transactions contained in the Ruling constitute a complete and accurate disclosure of all the relevant facts, purposes of the proposed transactions and the proposed transactions, we rule that: * The carrying value of Parent's investment in shares or long-term debt of Newco at the end of the taxation year of Parent that includes the Transaction Date will be deductible by Parent in calculating its taxable capital for that taxation year in accordance with subsection 181.3(2) and section 190.12. Amendments to rulings given in the Ruling * Ruling (f)(iv) will be amended by deleting "subsection 112(2.1)" after "in the case of Newco" and replacing it with "subsection 112(1)" * Ruling (h) of the Ruling will be amended by adding the following sentence: For greater certainty, the Proposed Transactions, including the additional Proposed Transaction described herein, in and by themselves, will not be considered to result in a disposition or increase in interest described in subparagraphs 55(3)(a)(i) to (v) with respect to the deemed dividends referred to in ruling (f). ...

Ce montant sera d'environ XXXXXXXXXX $. 5. Selon la nouvelle convention qui régira son contrat d'emploi après le XXXXXXXXXX, Mme A ne participera à aucun fonds de pension ni à aucun autre régime d'avantages sociaux de son employeur. ... Vous nous avez aussi demandé de vous confirmer que le montant de XXXXXXXXXX $ qui est fait mention au paragraphe 4 et que le Conseil scolaire versera à Mme A pourra être transféré à son régime enregistré d'épargne-retraite selon les modalités et dans les limites prévues à l'alinéa 60j.1) de la Loi. ... À notre avis, le montant de XXXXXXXXXX $ qui est fait mention au paragraphe 4 et que le Conseil scolaire versera à Mme A sera un revenu d'emploi qui devra être inclus dans le calcul de son revenu pour l'année où il sera reçu en vertu du paragraphe 5(1) de la Loi. ...

All or substantially all of the assets of Holdco are active business assets or the shares of Opco throughout the 24 month period at the determination time; 2.     More than 50% of the fair market value of the assets of Opco are active business assets throughout the 24 month period ending at the determination time; 3.     Less than all or substantially all of the assets are active business assets for a period of time during the 24 month period ending at the determination time; 4.      ...

USCo owns XXXXXXXXXX % of the shares of Canco and Foreignco owns the remaining XXXXXXXXXX %. ...