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XXXXXXXXXX 2022-094120 XXXXXXXXXX, 2022 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling – Loss Consolidation Arrangement (2022-094120) XXXXXXXXXX This is in reply to your letter dated XXXXXXXXXX, as amended XXXXXXXXXX, in which you requested an advance income tax ruling (the “Ruling”) on behalf of the above named taxpayers (the “Taxpayers”). ...

The estimated tax refund of federal and provincial income taxes to Profitco 1 as a result of the Proposed Transactions is as follows (all amounts are in $ XXXXXXXXXX): XXXXXXXXXX 39. ...

These shares were subsequently transferred to the Senior Trust – an alter ego trust. ...

Provided that immediately after the Proposed Transactions REIT # 1 shall own all of the assets that Taxpayer previously owned, directly or indirectly, immediately before the Proposed Transactions, the provisions of subsections 15(1), 56(2), 56(4), 69(1), 69(4), 105(1) and 246(1) will not apply as a result of the Proposed Transactions, in and by themselves. ...

The FMV of the marketable security portfolio held by DC is approximately $XXXXXXXXXX and of that, over XXXXXXXXXX % represents shares held in the capital stock of Investco A, Investco B, and Investco C. 2. ...

2006 Ruling 2006-0178401R3- 132.2 reorganization of a mutual fund trust Unedited CRA Tags 132.2 97(2) 85(1) 253.1 Principal Issues: Reorganization of an existing mutual fund trust, trust- on-corporation structure to a trust-on-partnership structure using rollovers available under s. 85, s.97 and 132.2; Additional issues encountered include deductibility of interest; debt forgiveness; acb of partnership interest & status of the mutual fund trust. ...

The fair market value, immediately before the Spin-off described in Paragraph 59, of each Participant's shares of the capital stock of Spinco will be equal to the amount determined by the formula: (A x B/C) + D as set out in subparagraph (b)(iii) of the definition "permitted exchange" in subsection 55(1). ...

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

On XXXXXXXXXX, HLP and HOLDCO closed a debt private placement with a third party for $XXXXXXXXXX in senior secured long term debt at a fixed rate of interest of XXXXXXXXXX %. ...

The issued and outstanding shares of DC are held as follows: Shareholder Number & Class of Shares Transferee1 XXXXXXXXXX Class A Shares Transferee1 XXXXXXXXXX Class C Shares Transferee2 XXXXXXXXXX Class C Shares Transferee1 XXXXXXXXXX Common Shares Transferee2 XXXXXXXXXX Common Shares Transferee1 controls DC by virtue of its XXXXXXXXXX Class A Shares and XXXXXXXXXX Common Shares. ...