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XXXXXXXXXX 2021-088901 XXXXXXXXXX, 2021 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request – Redemption of Mutual Fund Trust Units Held by Registered Plans XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX requesting an advance income tax ruling (“Ruling”) on behalf of the above-named Taxpayer. ...

The number and classes of such shares and their FMV immediately before the Deceased’s death were as follows: Type of shares Class # of shares FMV Common Class 1 XXXXXXXXXX XXXXXXXXXX Common Class 2 XXXXXXXXXX XXXXXXXXXX Special Class A XXXXXXXXXX XXXXXXXXXX Special Class B XXXXXXXXXX XXXXXXXXXX Special Class C XXXXXXXXXX XXXXXXXXXX 6. ...

Step 9 – there is no non-resident vendor and the purchaser is Taxpayer 6 for the acquisition of all issued and outstanding common shares of Taxpayer 11. 21. ...

The tax attributes attached to the shares of Opco immediately before the Deceased’s death were as follows: Shareholder Number & Class of FMV ACB PUC Shares of Opco Deceased XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Deceased XXXXX Opco Class E Special Shares XXXXX XXXXXX XXXXX Deceased XXXXX Opco Class F Special Shares XXXXX XXXXXX XXXXX Deceased XXXXX Opco Class Z Special Shares XXXXX XXXXXX XXXXX Child 1 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Child 2 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Child 5 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Child 6 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Child 7 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX 7. ...

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 ...