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In May 2014, the NEB issued the MH-001-2013 Reasons for Decisions – Set-aside and collection mechanisms (Pipeline Abandonment- Financial Issues) (the “SAM/COM Decision”), which required certain NEB-regulated pipeline companies to have a set-aside mechanism in place by January 1, 2015, and to begin accumulating funds to pay for pipeline reclamation. 4. ... Yours truly, XXXXXXXXXX Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

Immediately prior to the time of the Deceased’s death, there were XXXXXXXXXX Opco Common Shares, XXXXXXXXXX Opco Class A Preference Shares, XXXXXXXXXX Opco Class B Preference Shares, XXXXXXXXXX Opco Class C Preference Shares, XXXXXXXXXX Opco Class D Preference Shares, XXXXXXXXXX Opco Class E Preference Shares, XXXXXXXXXX Opco Class F Preference Shares, XXXXXXXXXX Opco Class G Preference Shares, XXXXXXXXXX Opco Class A Special Shares and XXXXXXXXXX Opco Class B Special Shares, issued and outstanding, which were owned, and which had a FMV, ACB and PUC, as set forth below: Shareholder Number & Class FMV ACB PUC of Shares of Opco Deceased XXXXX Opco Common XXXXX XXXXX XXXXX Shares Deceased XXXXX Opco Class A XXXXX XXXXX XXXXX Preference Shares Deceased XXXXX Opco Class B XXXXX XXXXX XXXXX Preference Shares Deceased XXXXX Opco Class C XXXXX XXXXX XXXXX Preference Shares Deceased XXXXX Opco Class D XXXXX XXXXX XXXXX Preference Shares Deceased XXXXX Opco Class F XXXXX XXXXX XXXXX Preference Shares Deceased XXXXX Opco Class G XXXXX XXXXX XXXXX Preference Shares Deceased XXXXX Opco Class A XXXXX XXXXX XXXXX Special Shares Deceased XXXXX Opco Class B XXXXX XXXXX XXXXX Special Shares Child 1 XXXXX Opco Class B XXXXX XXXXX XXXXX Preference Shares Child 1 XXXXX Opco Class G XXXXX XXXXX XXXXX Preference Shares Child 1 XXXXX Opco Class B XXXXX XXXXX XXXXX Special Shares Child 2 XXXXX Opco Class B XXXXX XXXXX XXXXX Preference Shares Child 2 XXXXX Opco Class G XXXXX XXXXX XXXXX Preference Shares Child 2 XXXXX Opco Class B XXXXX XXXXX XXXXX Special Shares Holdco XXXXX Opco Class E XXXXX XXXXX XXXXX Preference Shares On XXXXXXXXXX, Child2 transferred all of XXXXXXXXXX shares of Opco to a corporation controlled by Child2, in which the Estate has no interest. ... As a consequence, under subsection 70(5) of the Act, immediately before his death the Deceased was deemed to have disposed of the shares of Opco owned by him, and the Estate was deemed to have acquired such shares, at the FMV of such shares as set forth below: Number & Class of Shares of Opco FMV Immediately owned by the Deceased Before the Deceased Death XXXXX Opco Common Shares XXXXX XXXXX Opco Class A Preference Shares XXXXX XXXXX Opco Class B Preference Shares XXXXX XXXXX Opco Class C Preference Shares XXXXX XXXXX Opco Class D Preference Shares XXXXX XXXXX Opco Class F Preference Shares XXXXX XXXXX Opco Class G Preference Shares XXXXX XXXXX Opco Class A Special Shares XXXXX XXXXX Opco Class B Special Shares XXXXX 7. ...

P-Note 2 will be due within three years of the closing of the Proposed Transactions; “PUC” means “paid-up capital” as that term is defined in subsection 89(1) of the Act; “Proposed Transactions” means the transactions described in Paragraphs 45 to 54; “related person”, or persons related to each other, has the meaning assigned by subsection 251(2); “Safe Income” means, with respect to a taxable dividend described in paragraph 55(2.1)(a) that is received by a dividend recipient from a dividend payer, the amount of income earned or realized by a corporation — after 1971 and before the safe income determination time with respect to the transaction, event or series of transactions or events — that could reasonably be considered to contribute to the capital gain that would have been realized upon a disposition at FMV, made immediately before the dividend, of the share on which the dividend was received; “Sequential Butterflies” means the First Butterfly, the Second Butterfly and the Third Butterfly, referred to collectively; “TCC” means “taxable Canadian corporation” and has the meaning assigned by subsection 89(1); “Tco” means XXXXXXXXXX, a public corporation created under the BCA3, the shares of which are publicly traded; “Xco” means XXXXXXXXXX, a corporation incorporated under the BCA1, as described in Paragraph 163 of the Initial Ruling; “Yco” means XXXXXXXXXX, a corporation incorporated under the BCA1, as described in Paragraph 170 of the Initial Ruling; “Yco Management Employee 1” is an individual resident in Canada for the purposes of the Act who owns shares in a holding corporation owning shares in Yco and who also owns shares directly in Yco; “Yco Management Employee 2” means an employee of Yco who is an individual resident in Canada for the purposes of the Act and who is not related to Yco; “Yco Management Employee 3” means an employee of Yco who is an individual resident in Canada for the purposes of the Act and who is not related to Yco; “Yco Management Employee 4” means an employee of Yco who is an individual resident in Canada for the purposes of the Act and who is not related to Yco; “Yco Management Employee 5” means an employee of Yco who is an individual resident in Canada for the purposes of the Act and who is not related to Yco; and “Yco Management Employee 6” means an employee of Yco who is an individual resident in Canada for the purposes of the Act and who is not related to Yco. ...

Provided that, as part of the series of transactions or events that includes the proposed transactions, there is not: \* MERGEFORMAT \* MERGEFORMAT (i) a disposition of property in the circumstances described in subparagraph 55(3.1)(b)(i); (ii) an acquisition of control in the circumstances described in subparagraph 55(3.1)(b)(ii); or (iii) an acquisition of property in the circumstances described in paragraph 55(3.1)(c) or (d); which has not been described herein, then by virtue of paragraph 55(3)(b), subsection 55(2) will not apply to the taxable dividends referred to in the rulings given in I and K above and, for greater certainty, subsection 55(3.1) will not apply to deny the exemption under paragraph 55(3)(b). ...

The aggregate FMV, immediately before the Distribution, of the Foreign Spinco Common Shares owned by Foreign Services will be equal to or approximate the amount determined by the formula: (A × B/C) + D as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1) on the assumption that Foreign Services is the participant, DC is the distributing corporation and Foreign Spinco is the acquiror. ...

The aggregate FMV, immediately before the transfer of property by Canadian DC to Canadian TC described in Paragraph 120, of the common shares of the capital stock of New DC owned by Forco 23 will be equal to or approximate the amount determined by the formula, on the assumption that Forco 23 is the participant, Canadian DC is the distributing corporation and New DC is the acquiror, (A × B/C) + D as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1). 117. ... The aggregate FMV, immediately before the transfer of property by New DC to New TC described in Paragraph 135, of the shares of New DC owned by Forco 14 will be equal to or approximate the amount determined by the formula, on the assumption that Forco 14 is the participant, New DC is the distributing corporation and New Global Holdco is the acquiror, (A × B/C) + D as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1). 135. ...

As minor & unborn children were involved the value of the contingent capital interests were determined & set aside in a separate trust. ...

For the purpose of this ruling letter, the above related entities will collectively be referred to as the "XXXXXXXXXX Group". 7.The taxation services office ("TSO"), the taxation centre ("TC"), and the Revenue Canada account number ("RCT #") of the various members of the XXXXXXXXXX Group and XXXXXXXXXX are as follows: CorporationTSO/TCRCT # XXXXXXXXXX 8.XXXXXXXXXX is a taxable Canadian corporation and a public corporation, as those expressions are defined in subsection 89(1), whose shares are listed for trading on the XXXXXXXXXX. ...

" means XXXXXXXXXX; (x.2) "Q1 XXXXXXXXXX " means the new XXXXXXXXXX company to be incorporated and subsequently amalgamated with Q1 Ltd.; (y.2) "Q2 Ltd. ... " means XXXXXXXXXX, a wholly owned subsidiary of DC2; (c.3) "Q3 Amalco" means the amalgamated XXXXXXXXXX company formed on the amalgamation of Q3 Ltd. and Q3XXXXXXXXXX; (d.3) "Q3 XXXXXXXXXX " means the new XXXXXXXXXX company to be incorporated and subsequently amalgamated with Q3 Ltd.; (e.3) "Q4 Ltd. ... Immediately after the share exchanges described herein, the FMV of the shares of TC2 owned by each holder of TC2 shares will be equal to or approximate the amount determined by the formula: (A x B/C) + D as found in subparagraph (b)(iii) of the definition of "permitted exchange" in subsection 55(1). ...

For each calendar year in which an Emitter has not reduced its GHG emissions by the required amount, the Emitter will be required to compute and pay to the Fund a CCP equal to the positive amount calculated in accordance with the following formula: CCP = XXXXXXXXXX where: A is the Emitter's actual GHG emissions level for the year; P is the Emitter's GHG emissions level for the year as prescribed in the Draft Climate Regulations after the application of the reductions required by the Draft Climate Regulations; O is any offset credit utilized by the Emitter for the year towards achievement of its required reductions; PC is the number of tonnes of CO2e of Performance Credits utilized by the Emitter for the year towards the achievement of its required reductions; PCI is the number of tonnes of CO2e allocated to the Emitter by the Minister as a result of investment by that Emitter in a Pre-Certified Investment that the Emitter is able to include during the year towards the achievement of its required reductions; REA is the number of tonnes of CO2e allocated to the Emitter by the Minister with respect to recognition for early action that the Emitter is able to include in the year towards the achievement of its required reductions; OC is the amount of other tonnes of CO2e that the Minister permits the Emitter to deduct; and C is the XXXXXXXXXX as prescribed in the Draft Climate Regulations. 51. ... An Emitter for the purpose of the Climate Act will include industrial facilities as follows: (a) electricity generation; (b) petroleum refining facilities; (c) oil sands facilities; (d) pulp and paper facilities (e) steel production facilities; (f) natural gas pipelines – facility based with a minimum of 50 kt CO2e per year; (g) upstream oil and gas facilities – facility based with a minimum threshold of 50 kt CO2e per year; (h) fertilizer plants – facility based with a minimum threshold of 50 kt CO2e per year; (i) chemical plants- facility based with a minimum threshold of 50 kt CO2e per year; (j) potash mines- facility based with a minimum threshold of 100 kt CO2e per year; (k) coal carbonizing plants- facility based with a minimum threshold of 50 kt CO2e per year; (l) Ethanol plants, biodiesel facilities or canola crushing plants. ...