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

The relevant facts can generally be summarized as follows: In XXXXXXXXXX, XXXXXXXXXX and its subsidiaries ("XXXXXXXXXX ") applied for and received protection under the CCAA. ...

The Queen 99 DTC 5669 [SCC] and Stewart v The Queen 2002 DTC 6969 "XXXXXXXXXX " However, we have been unable to identify any comments in either of these decisions that support the Representative's position. ...

It is estimated that XXXXXXXXXX% of users at Existing Facilities (other than Centre 4) drive themselves, with the remaining XXXXXXXXXX % either walking or relying on public transit. 9. ...

In the Macmillan-Bloedel decision, the judge stated: "... when one carefully analyzes the situation, there are, from a business and accounting view, two transactions. ...

DEFINITIONS In this letter, the following terms are defined as follows: (a) "A Co" means XXXXXXXXXX; (b) "A Co Shareholder" means a beneficial owner of one or more A Co common shares but does not include a XXXXXXXXXX; (c) XXXXXXXXXX; (d) "ACB" means adjusted cost base and has the meaning assigned by section 54 of the Act; (e) "AcquisitionCo" means XXXXXXXXXX, a Taxable Canadian Corporation incorporated under the XXXXXXXXXX, all of the shares of which are held by LP; (f) "Additional Interest" will be payable annually by the Debtor and will be equal to the lesser of a specific percentage amount of the outstanding principal amount of the Debt, currently estimated to be XXXXXXXXXX% per annum (being an amount intended to increase the effective interest rate on the Debt to the prevailing market rate of interest for comparable debt), and an amount equal to the taxable income of the Debtor minus $XXXXXXXXXX calculated without regard to the Additional Interest component; (g) XXXXXXXXXX; (h) "Base Interest" means interest at a fixed rate, currently estimated to be XXXXXXXXXX% per annum, of the outstanding principal amount of the Debt that will be payable annually by the Debtor; (i) "Combination" means the proposed combination into one corporation, (XXXXXXXXXX) of all assets and liabilities of AcquisitionCo, A Co, the XXXXXXXXXX and the subsidiaries by way of the amalgamation of such corporations under subsection 87(1) of the Act; (j) "CombinationCo" means the corporation that will be created as a result of the amalgamation of AcquisitionCo, A Co, the XXXXXXXXXX and the subsidiaries; (k) "CRA" means the Canada Revenue Agency; (l) "Debt" means the debt to be issued by AcquisitionCo to LP as outlined in the Proposed Transactions, the terms and conditions of which will include interest at a maximum rate, currently estimated to be XXXXXXXXXX% per annum, payable annually and comprised of (i) Base Interest, and (ii) Additional Interest; with any Interest that has become payable but has not been paid within a specified period of time being added to the principal amount of the Debt then outstanding; (m) "Debtor" means the debtor under the Debt, which initially will be AcquisitionCo and as more fully outlined under the Proposed Transactions, will be CombinationCo when certain corporations are amalgamated with AcquisitionCo; (n) "FMV" means fair market value; (o) "GAAR" means the general anti-avoidance rule under section 245 of the Act; (p) "GPCo" means a Taxable Canadian Corporation incorporated under the XXXXXXXXXX to function as administrator of the MFT and the Trust, the general partner of LP, and whose share capital is wholly-owned by the MFT; (q) "XXXXXXXXXX" means a Taxable Canadian Corporation incorporated under the XXXXXXXXXX, all or substantially all of the assets of which will be common shares of XXXXXXXXXX; (r) "XXXXXXXXXX" means a person that beneficially owns one or more XXXXXXXXXX; (s) "XXXXXXXXXX" means shares in the capital of XXXXXXXXXX; (t) "Indenture" means the declaration of trust to be made by the trustee of the Trust to, among other things, hold in trust any and all property of the Trust and any income and gains therefrom for the benefit of the beneficiary of the Trust; (u) "Interest" means the interest payable in respect of the principal amount owing under the Debt from time to time, comprised of the Base Interest plus the Additional Interest; (v) "LP" means a limited partnership formed under the XXXXXXXXXX pursuant to the LP Agreement; (w) "LP Agreement" means the written partnership agreement entered into between GPCo, as general partner, and the Trust as limited partner of the LP; (x) "LP Unit" means an interest in the LP's capital issued pursuant to the terms of the LP Agreement; (y) "mutual fund trust" has the meaning assigned by subsection 132(6); (z) "MFT" means a mutual fund trust created and governed under the laws of the Province of XXXXXXXXXX and formed pursuant to the MFT Indenture; (aa) "MFT Indenture" means the declaration of trust made by the trustee of MFT to, among others, hold in trust any and all property of the MFT and any income and gains therefrom, for the benefit of the MFT Unitholders; (bb) "MFT Unitholder" means a holder of a MFT Unit; (cc) "MFT Unit" means a trust unit of MFT, each such unit representing an equal fractional undivided beneficial interest in any distributions from the MFT and in any net assets of the MFT in the event of termination of the MFT; (dd) "XXXXXXXXXX Partnership" means a partnership formed under the XXXXXXXXXX pursuant to a written partnership agreement having a PartnerCo and one or more subsidiaries as its only partners; (ee) "Option" means an option to acquire an A Co common share pursuant to an agreement as contemplated under subsection 7(1) of the Act; (ff) "PartnerCos" means those Taxable Canadian Corporations, each of which is wholly-owned indirectly by MFT, that hold an interest in one or more of the XXXXXXXXXX Partnerships and that will remain as separate corporations holding such direct interest in one or more of the XXXXXXXXXX Partnerships after the Combination; (gg) "Proposed Transactions" means those transactions and events described in paragraphs 13 to 17; (hh) "Public Corporation" has the meaning assigned by subsection 89(1) of the Act; (ii) "XXXXXXXXXX " means those Taxable Canadian Corporations formed under the XXXXXXXXXX that are either wholly-owned by A Co or another subsidiary; (jj) "Taxable Canadian Corporation" has the meaning assigned by subsection 89(1) of the Act; (kk) "Trust" means an inter vivos trust for purposes of the Act, to be created and governed under the laws of the Province of XXXXXXXXXX, the sole beneficiary of which will be the MFT; (ll) "Trust Note" means a promissory note evidencing a debt obligation issued by the trustee of Trust in accordance with the Trust Indenture; and (mm) XXXXXXXXXX. ...

The relevant facts regarding the US Group's business carried on in the US as of, or in respect of, the US Group's financial years ending XXXXXXXXXX, are as follows: * XXXXXXXXXX. ...

The transactions must also be in full technical compliance with relevant provisions of the Act, including paragraph 20(1)(c) where interest expense deductions are claimed and subsections 112(1) – (2.4) if relying on inter-corporate dividend deductions. ...

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

$XXXXXXXXXX ÷ U.S.$XXXXXXXXXX) would have been issued. This differential likely indicates that the conversion did not occur pursuant to the terms of the Notes. ...