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The shares of Sub2 are XXXXXXXXXX % owned by Opco1 and XXXXXXXXXX% owned by Sub1, which is a wholly-owned subsidiary of Opco1. ... The favourable vote of at least XXXXXXXXXX % of the votes cast by those in attendance or by proxy is required. ...

DEFINITIONS In this letter, the following definitions are used: (a) "ACB", or " adjusted cost base", has the meaning in section 54 of the Act; (b) "Act" means the Income Tax Act, R.S.C. 1985 (5th Suppl.) c.1, as amended to the date hereof; (c) "arm's length" has the meaning in section 251 of the Act; (d) "Arrangement" has the meaning set out in Paragraph 3; (e) "Canadian Acquisition Co" means a new corporation that Canco will incorporate under the Corporate Act. ... The current shareholders of Canco will hold more than XXXXXXXXXX % of the Canco common shares after the purchase so that there will be an acquisition of Canadian Target for purposes of the Act. ...

an amount, determined for each such period, as XXXXXXXXXX % per annum of the Principal Amount, and Canco will undertake to make periodic payments to the Issuer Trustee (the "Periodic Canco Swap Payments") calculated as the amounts, if any, by which:? an amount determined for each such period, as XXXXXXXXXX % per annum applied to the Principal Amount, exceeds? ...

In consideration for the services rendered by the Corporation, the Investors have agreed to pay a management fee to the Corporation equal to $XXXXXXXXXX, plus an annual monitoring fee equal to XXXXXXXXXX % of the amount of the investments made by them and not written off. In addition, the Investors have agreed to provide the Corporation with an option (the "Investor Option") to acquire XXXXXXXXXX % of the Investors' investments in the Targets for an exercise price equal to the Investors' respective cost of their interests in the Targets. ...

The annual interest rate under the Proposed Loan Agreement shall be equal to LIBOR + an applicable Margin payable semi-annually. ... Yours truly, XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch ...

The following terms are defined in the Trust Agreement or the Settlement Agreement and are used herein: Band Benefit Band Development Band Member Band Project Beneficiary Council Rectification Committee Rectification Fund Rectification Trust Fund = the name used in the Settlement Agreement for the Rectification Fund Reserve Settlement Agreement Settlement Monies Trust = XXXXXXXXXX Trust Agreement Trust Capital Account Trust Revenue Account Trustee Our understanding of the facts, proposed transactions and the purpose of the proposed transactions is as follows: FACTS 1. ...

XXXXXXXXXX/Aco directly owns a number of Class XXXXXXXXXX shares of XXXXXXXXXX/Cco representing XXXXXXXXX % of the votes and XXXXXXXXXX% of the total equity. ... XXXXXXXXXX/Cco holds XXXXXXXXXX % of XXXXXXXXXX/Dco's issued and outstanding common shares. ...

The main terms and conditions of the borrowing provide for interest to accrue at a floating rate of XXXXXXXXXX %. ... Newco will at all times retain sufficient cash to meet its liabilities under the Act and, in particular, will remit to the Receiver General of Canada non-resident tax under Part XIII of the Act on all dividends that it pays or credits to USco, at the rate of XXXXXXXXXX % of the amounts so paid or credited from time to time, except to the extent that Newco elects to have any such amount treated as a "capital gains dividend" within the meaning of subsection 133(7.1). 18. ...

XXXXXXXXXX 2019-083490 XXXXXXXXXX Dear XXXXXXXXXX: Re: CONTAINS TAXPAYER INFORMATION Advance Income Tax Ruling Request – Loss Utilization XXXXXXXXXX (collectively referred to as the “Taxpayers”) This is in reply to your letter dated XXXXXXXXXX (the “Request”) in which you requested an advance income tax ruling (“Ruling”) on behalf of the Taxpayers. ... “Profitco” means XXXXXXXXXX, a corporation formed under the BCA; “Profitco Note” means the promissory note issued by Profitco as described in Paragraph 23; “Profitco Preferred Shares” means the shares issued in the transaction described in Paragraph 20; “specified financial institution” has the meaning assigned by subsection 248(1); “Subco1” means XXXXXXXXXX, a corporation formed under the Companies Act; “Subco2 ” means XXXXXXXXXX; “Subco2 Amalco” means XXXXXXXXXX, which is the corporate entity formed as a result of the amalgamation of Subco2 and Subco3; “Subco2 Amalco Shares” means the common shares of Subco2 Amalco described in Paragraph 14; “Subco3” means XXXXXXXXXX; “Subco4” means XXXXXXXXXX; “Subject Transactions” means the transactions described in Paragraphs 18 to 26; “taxable Canadian corporation” has the meaning assigned by subsection 89(1); “Transferred Assets” refers to the assets described in Paragraph 18; “UCC” means “undepreciated capital cost” and has the meaning assigned by subsection 13(21); and XXXXXXXXXX FACTS 1. ...

The following chart illustrates the current issued and outstanding shares of DC: Common Shares Preferred Shares Name Class #of Shares % of Shares Class # of Shares $ of Shares Shareholder1 Class D XXXXX XXXXX Class A XXXXX XXXXX Class B XXXXX XXXXX Class C XXXXX XXXXX Shareholder2 Class D XXXXX XXXXX Class A XXXXX XXXXX Class B XXXXX XXXXX Class C XXXXX XXXXX Shareholder3 Class D XXXXX XXXXX Class A XXXXX XXXXX Shareholder4 Class D XXXXX XXXXX Class A XXXXX XXXXX Shareholder5 Class A XXXXX XXXXX CorpShareholder1 (owned by Shareholder1) Class A XXXXX XXXXX Class B XXXXX XXXXX CorpShareholder2 (owned by Shareholder1) Class B XXXXX XXXXX 5. ...