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On a particular day in late XXXXXXXXXX, each of Newlossco3 and Newlossco4 will issue demand notes payable, bearing interest at a rate of XXXXXXXXXX %, the Newlossco3 Note A and Newlossco4 Note A, respectively, to Opco for cash in the amount of the non-capital losses of each of Newlossco3 and Newlossco4 at that time (which will approximate the interest expense incurred by each of Newlossco3 and Newlossco4 on the Newlossco3 Note and Newlossco4 Note, respectively). 47. ...

XXXXXXXXXX 2021-089667 XXXXXXXXXX Dear XXXXXXXXXX, Re: Advance Income Tax Ruling – Sequential butterfly reorganizations XXXXXXXXXX (Collectively referred to as the “Taxpayers”) We are writing in response to your request for an advance income tax ruling (“Ruling request”) dated XXXXXXXXXX, and revised on XXXXXXXXXX, on behalf of the above-noted Taxpayers. ...