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XXXXXXXXXX 2014-056322 XXXXXXXXXX, 2015 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX Further to your request for an amendment to our Advance Income Tax Ruling dated XXXXXXXXXX 2014, our file number 2014-0539791R3 (the "Ruling"), issued to the above named taxpayer, the Ruling is amended by: (1) Adding the following paragraph in the Definition section of the Ruling after paragraph (h): "(h.1) "Hedge Fund" means XXXXXXXXXX, a fund resident in XXXXXXXXXX;". (2) Amending the definition of "Non-Resident Holders" in paragraph (l) by replacing the words "and certain of its subsidiaries" with the words ", certain subsidiaries of the Bank, and the Hedge Fund;". (3) Amending the definition of "Settlement Agreement" in paragraph (t) by replacing the words "the Non-Resident Noteholders" with the words "the Bank and certain of its subsidiaries". (4) Amending paragraph 11 by replacing the words "the Non-Resident Noteholders" with the words "the Bank and certain of its subsidiaries". (5) Amending paragraph 15 by: (a) Replacing the words "The Non-Resident Noteholders" in the second sentence with the words "The Bank and certain of its subsidiaries"; (b) Adding the sentence "The Hedge Fund held XXXXXXXXXX% of the Notes outstanding. ...

XXXXXXXXXX 2004-010939 XXXXXXXXXX, 2005 Dear Sir: Re: Supplemental Advance Income Tax Ruling Request XXXXXXXXXX (the "Taxpayers") Further to your letter of XXXXXXXXXX, the following amendments are made to advance income tax ruling 2004-006027 that was issued to the Taxpayers on XXXXXXXXXX, 2004 (the "Ruling"): (a) paragraph 1(v) of the DEFINITIONS is deleted; (b) the references to "GCO", "XXXXXXXXXX Class G Preference" shares and "XXXXXXXXXX Class H Preference" shares in paragraph 4 are deleted; (c) the reference to "XXXXXXXXXX Class C Preference" shares in paragraph 4 of the Ruling is deleted and replaced with a reference to "XXXXXXXXXX Class E Preference" shares; (d) paragraph 5 is deleted; (e) paragraph 6 of the Ruling is deleted and replaced with " XCO is the sole shareholder of a number of subsidiary companies (the "Subsidiaries"), the shares of which are held by XCO as capital property for the purposes of the Act (the "Subsidiary Shares"); (f) the reference to "GCO," in paragraph 14 is deleted; (g) paragraph 48 is deleted; and (h) paragraph 1(d) of the COMMENTS is deleted and replaced with "any tax consequences relating to the facts and the proposed transactions described herein other than those described in the rulings given above". ...

XXXXXXXXXX 2005-014474 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX XXXXXXXXXX This is in reply to your facsimile dated XXXXXXXXXX in which you requested amendments to the facts and proposed transactions set out in the Advance Income Tax Ruling letter (document # 2005-011909) issued to the above-referenced taxpayers on XXXXXXXXXX, 2005 (the "Ruling"). ...

Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

XXXXXXXXXX 2005-011790 XXXXXXXXXX, 2005 Dear Messrs: Re: Advance Income Tax Ruling XXXXXXXXXX (XXXXXXXXXX Tax Services Office, XXXXXXXXXX Taxation Centre) XXXXXXXXXX (XXXXXXXXXX Tax Services Office, XXXXXXXXXX Taxation Centre) This is in reply to our conversation dated XXXXXXXXXX in which you requested amendments to the rulings set out in the Advance Income Tax Ruling letter (document # 2005-011790) issued to the above-referenced taxpayers on XXXXXXXXXX 2005 (the Ruling). ...

Position: No Reasons: prior wording of reg. 5000(7) parallels wording in 108(2)(b); Finance saw fit to amend the definition of pooled fund trust because they were of the opinion that "special warrants" & other such convertibles did not fit the category of marketable securities; therefore no ruling given; discussions with Finance indicate amendment to 108(2)(b) is coming that will mirror the changes made to ss. 5000(7) of the Regulations; therefore decline to rule amendment to Act required. 964172 XXXXXXXXXX L. ...

Reasons FOR POSITION:position on 110(1)(d) & 7(3)(b) under review. payment taxable when election made. ...

28 May 1993 Ruling 9313173 F- Retiring Allowance Re-employment Unedited CRA Tags 56(1)(a(ii), 248(1) Retiring allowance   XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Advance Ruling Request XXXXXXXXXX This is in reply to your letter of May 5, 1993 requesting an advance income tax ruling concerning amounts paid to certain individuals by the XXXXXXXXXX on termination of their employment. ...

22 April 1993 Ruling 9311411 F- Stripped Bonds Unedited CRA Tags 12(4), 12(9), ITR 7000, 20(14)   QUESTION See attached letter from XXXXXXXXXX to XXXXXXXXXX, dated April 8, 1993, concerning the proper taxation of stipped bonds. ...

15 November 1993 Ruling 9231471 F- Prepaid Funeral Services Unedited CRA Tags 75(2), 20(1)(c), 104   XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Prepaid Funeral Services We are writing to advise you of the Department's current position concerning the taxation of interest received on funds held in trust to provide funeral services. ...