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

The issued and outstanding shares of DC are owned as follows: Shareholder Common Shares Preferred Shares % of Class Individual1 XXXXXXXX XXXXXXXX XXXXXXXX Holdco1 XXXXXXXX XXXXXXXX XXXXXXXX Individual2 XXXXXXXX XXXXXXXX XXXXXXXX Holdco2 XXXXXXXX XXXXXXXX XXXXXXXX Individual3 XXXXXXXX XXXXXXXX XXXXXXXX Holdco3 XXXXXXXX XXXXXXXX XXXXXXXX Individual4 XXXXXXXX XXXXXXXX XXXXXXXX Holdco4 XXXXXXXX XXXXXXXX XXXXXXXX Each of the shareholders of DC holds its shares of DC as capital property. ...

XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

The members of the Partnership are Opco (as to an approximate XXXXXXXXXX% interest), Sub 1 (as to an approximate XXXXXXXXXX % interest), Sub 3 (as to an approximate XXXXXXXXXX% interest) and Sub 2 (as to an approximate XXXXXXXXXX% interest). ...

To date XXXXXXXXXX Class C Shares owned by Sibling2 have been transferred to Holdco and redeemed by DC pursuant to the Class C Redemption Agreement as follows: DC's Taxation Year # of Class C Shares Redeemed XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Subtotal XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Total XXXXXXXXXX None of the above-described redemptions of Class C Shares have taken place in contemplation of, or in connection with, the Proposed Transactions. ...

XXXXXXXXXX 14.En date des présentes, les caractéristiques fiscales des actions émises et en circulation de XXXXXXXXXX sont les suivantes: Nombre d'actions Capital versé Prix de base rajusté Actions ordinaires XXXXXXXXXX 15.La direction de XXXXXXXXXX estime que la juste valeur marchande des actions de XXXXXXXXXX est approximativement de XXXXXXXXXX $. ...

The operating line is payable on demand and has an interest rate of prime + XXXXXXXXXX%. ...

As at XXXXXXXXXX, the value of the assets and liabilities of XXXXXXXXXX, after giving effect to the sale of the XXXXXXXXXX property described in paragraph 21 below and adjusting the value of XXXXXXXXXX real property to fair market value were as follows: XXXXXXXXXX ** Liabilities, immediately before the transfers of property described in paragraph 34 below (the "Butterfly Transfer"), will include an amount in respect of taxes payable as a consequence of the sale of the XXXXXXXXXX property and the transfer of inventory properties in the course of the proposed transactions. 8. ...

Immediately after the share-for-share exchange referred to in this Paragraph, the fair market value of the shares of the capital stock of XXXXXXXXXX Newco acquired by XXXXXXXXXX will equal or approximate the amount determined by the formula (A X B) + D C as found in paragraph (b)(iii) of the definition of permitted exchange. ...

Immediately after the share-for-share exchange referred to in this Paragraph, the fair market value of the shares of the capital stock of XXXXXXXXXX Newco acquired by XXXXXXXXXX will equal or approximate the amount determined by the formula (A X B) + D C as found in paragraph (b)(iii) of the definition of permitted exchange. ...