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XXXXXXXXXX 2024-100951 XXXXXXXXXX 2024 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling – Post-mortem pipeline XXXXXXXXXX We are writing in response to your request, dated XXXXXXXXXX, for an advance income tax ruling (Ruling) on behalf of the above-noted taxpayers. ...

XXXXXXXXXX 9.The XXXXXXXXXX units of XXXXXXXXXX are owned by over XXXXXXXXXX individuals and corporations that deal at arm's length with XXXXXXXXXX. 10.The TSO, taxation centre ("TC"), and the Revenue Canada account number ("RCT #") of the various members of XXXXXXXXXX are as follows: Corporation TSO\TC RCT # XXXXXXXXXX 11.XXXXXXXXXX is a taxable Canadian corporation and a public corporation whose shares are listed for trading on the XXXXXXXXXX exchange. ...

The aggregate FMV, immediately before the DC Transfer, of the Foreign Spinco XXXXXXXXXX owned by Forco 3 will be equal to or approximate the amount determined by the formula, on the assumption that Forco 3 is the participant, DC is the distributing corporation and Foreign Spinco is the acquiror, (A × B/C) + D as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1). ...

Holders may put the Convertible Senior Notes to TARGET in exchange for cash on XXXXXXXXXX at a purchase price equal to XXXXXXXXXX % of the principal amount plus accrued and unpaid interest. ... HOLDCO 1 and SHAREHOLDER 2-SUBCO 1 hold respectively XXXXXXXXXX % and XXXXXXXXXX% of the issued and outstanding shares of the capital stock of FINANCECO. ...

The DC Common Shares trade on the Stock Exchange under the symbol "XXXXXXXXXX ". ... The fair market value, immediately before the transfer described in Paragraph 28, of each Participant's Spinco Common Shares will equal or approximate the amount determined by the formula: (A x B/C) + D in respect of such Participant, as set out in subparagraph (b)(iii) of the definition "permitted exchange" in subsection 55(1). ...

The New Preferred Shares will: (a) be non-voting; (b) be redeemable by the corporation and retractable by the holder for the Redemption Amount; (c) entitle the holder to receive a non-cumulative dividend of XXXXXXXXXX % of the Redemption Amount per annum, preferential to dividends on the common shares and any other class of preferred shares of Opco but pari passu with each other series of New Preferred shares; and (d) on the liquidation, dissolution or winding-up of Opco, entitle the holder to receive the Redemption Amount before any amount will be paid or any assets of Opco will be distributed to the holders of common shares or any of the other classes of preferred shares of the corporation but ranking equally with the New Preferred Shares Series 1, New Preferred Shares Series 2 and New Preferred Shares Series 3; "Opco" means XXXXXXXXXX. ... Consequently, nothing in this ruling should be viewed as providing any assurance that LP is not currently a SIFT or will not become a SIFT by virtue of the proposed transactions; Yours truly, for the Director Reorganizations & Resources Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

., a corporation more fully described in Paragraph 19; "Spinco Commitment" means the commitment of Spinco in respect of the DC Warrants and the unpaid bonuses of DC Common Shares, as referred to in Paragraph 27; "Spinco Common Shares" means the common shares of Spinco, as described in Paragraph 19; "Spinco Redemption Note" means the promissory note to be issued by Spinco as described in Paragraph 32; "Spinco Reorganization Share Redemption Amount" has the meaning assigned by Paragraph 24(a); "Spinco Reorganization Shares" means the class of preferred shares in the capital of Spinco as described in Paragraph 24; "Spinco Stock Options" has the meaning assigned by Paragraph 26.1; "Spin-off Property" means XXXXXXXXXX % of the issued and outstanding shares of Newco following the transfer described in Paragraph 28 below; "stated capital" has the meaning assigned by the BCA; "Stock Exchange" means the XXXXXXXXXX Stock Exchange; "subject corporation" has the meaning assigned by subsection 186(3); "taxable Canadian corporation" has the meaning assigned by subsection 89(1); "taxable Canadian property" has the meaning assigned by subsection 248(1); "taxable dividend" has the meaning assigned by subsection 89(l); "taxable preferred share" has the meaning assigned by subsection 248(1); and "Transferred Properties" has the meaning assigned by Paragraph 2. ... The fair market value, immediately before the transfer described in Paragraph 29, of each Participant's Spinco Common Shares will equal or approximate the amount determined by the formula: (A x B/C) + D in respect of such Participant, as set out in subparagraph (b)(iii) of the definition "permitted exchange" in subsection 55(1). ...

The Newlossco3 Preferred Shares will be entitled to non-cumulative dividends not exceeding XXXXXXXXXX % of their redemption amount. ... The consideration will be a demand non-interest-bearing note (the " Newlossco2 Note B") with a principal amount and FMV equal to the redemption value of the Newlossco2 Preferred Share. ...

Immediately after the share-for-share exchange described herein, the fair market value of each DCAmalco Shareholder’s shares of the capital stock of Transferee1 will be equal to or approximate the amount determined by the formula (A x B) + D C as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1). ... Immediately after the share-for-share exchange described herein, the fair market value of each DCAmalco Shareholder’s shares of the capital stock of Transferee2 will be equal to or approximate the amount determined by the formula (A x B) + D C as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1). ...

Each of the DC Class A Preference Shares will have the following attributes: (a) will be non-voting and non-participating; (b) will be redeemable and retractable, subject to applicable law, at any time for an amount equal to the amount determined by dividing the aggregate FMV of the property received by the corporation on the issuance of the Class A Preference Shares, less the aggregate FMV of any non-share consideration issued or liabilities assumed by the corporation in connection with the issuance of such shares, by the number of the Class A Preference Shares issued ("DC Class A Redemption Amount"); (c) will be entitled to a fixed, preferential, non-cumulative monthly dividend of XXXXXXXXXX % of the DC Class A Redemption Amount, and (d) will rank in first priority over all other classes on dissolution. 10. ... Immediately after the share exchanges described in this paragraph, the aggregate FMV of the Newco Common Shares owned by the particular DC shareholder will be equal to or approximate the amount determined by the formula, on the assumption that Father, Mother, Son1, Son2 and Individual A are participants, DC is the distributing corporation and Newco is the acquirer, (A x B) + D C as found in subparagraph (b)(iii) of the definition of "permitted exchange" in subsection 55(1). ...