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The reduction in Royalty Income (the "Debt Service Charge") will be the aggregate of all interest payments relating to the borrowing of funds by XXXXXXXXXX and all principal repayments relating to such borrowing; and (c) pursuant to a request by XXXXXXXXXX primary corporate lender, the limitations on borrowing which previously existed (for example, not to exceed XXXXXXXXXX% of asset value or XXXXXXXXXX % of projected royalty income) were removed. 15. ... The amount of Other Revenue of XXXXXXXXXX, expressed as a percentage of total revenue, for XXXXXXXXXX and subsequent years: % of Total Revenue XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX 18. ... The Trust holds approximately XXXXXXXXXX % of the Royalty Units granted by XXXXXXXXXX. 30. ...

XXXXXXXXXX (the "Trust ") is an inter vivos family trust. It was established by an agreement (the "Trust Agreement") made between XXXXXXXXXX ("Father ") and his two sons, XXXXXXXXXX("Settlor A") and XXXXXXXXXX ("Settlor B"), as of XXXXXXXXXX. ... That as a result of the distributions of DC's property to NewcoA, NewcoB, Settlor A and Settlor B, on the winding-up of DC: (i) pursuant to paragraph 88(2)(b) and subsection 84(2), but subject to (ii) to (iv) herein, NewcoA, NewcoB, Settlor A and Settlor B will be deemed to have received a dividend (the ~ dividend") on their shares of DC equal to the proportion of the amount by which the aggregate fair market value of the property of DC distributed by DC to NewcoA, NewcoB, Settlor A and Settlor B on the winding-up exceeds the amount by which the PUC of the XXXXXXXXXX and XXXXXXXXXX shares of DC, as the case may be, is reduced as a result of the distribution that the number of shares of such class held by NewcoA, NewcoB, Settlor A and Settlor B, as the case may be, is of the number of issued shares of such class outstanding immediately before the distribution; (ii) pursuant to subparagraph 88(2)(b)(i), such portion of the winding-up dividend referred to in (i) herein as does not exceed DC's CDA determined immediately before the payment of the winding-up dividend shall be deemed, for the purposes of the subsection 83(2) election referred to in paragraph 12 above, to be the full amount of a separate dividend; (iii)pursuant to subparagraph 88(2)(b)(ii), the portion of the winding-up dividend that is equal to the lesser of: (A) DC's pre-1972 capital surplus on hand as determined immediately before the payment of the winding-up dividend, and (B) the amount by which the winding-up dividend exceeds the portion, if any, in respect of which DC will elect under subsection 83(2) shall be deemed not to be a dividend; and (iv) pursuant to subparagraph 88(2)(b)(iii), the winding-up dividend, to the extent that it exceeds the portion thereof referred to in (ii) herein that is deemed to be a separate dividend and the portion referred to in (iii) herein that is deemed not to be a dividend, shall be deemed to be a separate dividend that is a taxable dividend. ...

The XXXXXXXXXX letter MAP Settlement stated, in part, the following: a) “The settlement of the [MAP Adjustment], including the recording of a liability or receivable, is not required. […] Although not required, any settlement of the [MAP Adjustment] would be free of any withholding tax”. b) “No secondary adjustment shall be made in respect of the [MAP Adjustment] to i) the income of [Canco 1] or [Forco 1] or to ii) create a loan, deemed trust or other obligation between [Canco 1] and [Forco 1]”. c) “[Canco 1] waives any right of objection or appeal [to the MAP Taxation Years] in respect of the services provided by [Forco 1]”. 28. ... The XXXXXXXXXX APA Agreement from the Canadian Competent Authority stated, in part, the following: a) “the settlement of the [APA Adjustment], including the recording of a liability or receivable, is not required. […] Although not required, Canco 1 and Forco 1 may settle compensating adjustments by any method which they deem appropriate. […] In addition, any payment of a compensating adjustment will be made free of any withholding tax as the underlying Covered Transaction would not have been subject to withholding tax”. b) “No secondary adjustment will be made in respect of the [APA Adjustments] to i) the income of [ACo] or of [Forco 1] or to ii) create a loan, deemed trust or other obligation between Forco 1 and Canco 1”. c) Canco 1 waived any right to object or appeal in respect of the APA Adjustment for the APA Taxation Years. ...

XXXXXXXXXX of the Deed states: “The assets of each Sub-fund … shall be held by, or for the order of, the Depositary for and on behalf of its Unitholders from time to time.” ... XXXXXXXXXX of the Deed states: “Any reference in this Deed to Units being issued “in respect of” a Sub-fund or “relating” to a Sub-fund shall be construed as a reference to Units which give the holder of them co-ownership of that part of the XXXXXXXXXX Property comprising the Sub-fund in question and the entitlement […..] to exchange co-ownership of that part of the XXXXXXXXXX Property for that part of the XXXXXXXXXX Property comprising any other Sub-fund [....]." ...

XXXXXXXXXX 2022-093163 XXXXXXXXXX Dear XXXXXXXXXX Re: CONTAINS TAXPAYER INFORMATION Advance Income Tax Ruling – Loss Consolidation Arrangement (2022-093163) XXXXXXXXXX This is in reply to your letter dated XXXXXXXXXX, as amended XXXXXXXXXX, in which you requested an advance income tax ruling (the “Ruling”) on behalf of the above named taxpayers (the “Taxpayers”). ... Profitco’s taxable income from the three preceding taxation years and the estimated taxable income for the next three taxation years is as follows: Taxation Year Taxable Income – As Filed XXXXXXXXXX XXXXXXXXXX Taxation Year Estimated Taxable Income (excluding proposed interest) XXXXXXXXXX XXXXXXXXXX 3. ... The payment of the redemption price may be satisfied, at the issuer’s option, either by (i) payment of cash; or (ii) delivery of property having a fair market value at the time of redemption equal to the aggregate redemption price, in each case together with an amount in cash equal to all accrued and unpaid dividends (whether or not declared) to but excluding the date fixed for such redemption; and (d) entitlement to a cumulative dividend, payable semi-annually, calculated by reference to the redemption amount of Lossco Class A Preferred Shares at a rate estimated at XXXXXXXXXX% + XXXXXXXXXX% per annum (the “Lossco Class A Dividends”). ...

The Units will not have any voting rights (except the right, on written notice signed by Unitholders holding XXXXXXXXXX % of the Units of all of the Sub-Funds, to require the Manager to resign). ... Yours truly, for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Holdco will transfer XXXXXXXXXX % of the shares in the capital of BV to Newco in exchange for the issuance by Newco to Holdco of one additional common share in the capital of Newco. ... In one or more separate transfer(s), Holdco will transfer XXXXXXXXXX % of the shares in the capital of each of the FAcos to Newco in exchange for the issuance by Newco to Holdco of additional common shares in the capital of Newco. ...

CanCo owns approximately XXXXXXXXXX % of the common shares of ForeignCo, a corporation incorporated under the laws of XXXXXXXXXX and resident in that country for purposes of the Act. ... Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

Corp will also transfer approximately XXXXXXXXXX % of its Subordinated Units for shares of Newco. ... Yours truly, XXXXXXXXXX for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Variable Return is determined according to the following formula: Variable Return = Principal Amount x the greater of (i) Basket Appreciation, and (ii) zero. 9. ... An amount determined by multiplying (i) the value of the Fund Portfolio by (ii) a rate equal to XXXXXXXXXX % of the value weighted average of the quarterly distribution rates of the Funds on their Units will be notionally reinvested in the Reference Basket. 11. ...