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We also acknowledge the information provided in your letters and e-mails of XXXXXXXXXX, and during our various telephone conversations in connection with your ruling request (XXXXXXXXXX). ... Summary of the Transactions Undertaken in Connection with the Acquisition of Target By way of background, the sequence of transactions leading to the acquisition of Target by Bidco and the Target Winding-up can generally be summarized as follows: A. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

You have advised that to the best of your knowledge, and that of the responsible officers of each of the taxpayers, none of the issues involved in this Ruling is: (i) in an earlier return of any of the taxpayers or a related person; (ii) being considered by a tax services office (TSO) or taxation centre (TC) in connection with a previously filed tax return of any of the taxpayers or a related person; (iii) under objection by any of the taxpayers or a related person; (iv) before the courts or if a judgment has been issued the time limit for appeal to a higher court has expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... In connection with the DC Sub Share Exchange: (a) for the purposes of the BCA, the addition to the stated capital (and paid-up capital) of the DC Sub New Common Shares will be $XXXXXXXXXX and the addition to the stated capital (and paid-up capital) of the DC Sub Class C Shares will be $XXXXXXXXXX. ... In connection with the DC Share Exchange: (a) for the purpose of the BCA, the aggregate of the additions to the stated capital accounts of the DC New Common Shares and the DC Class C Shares will not exceed the paid-up capital of the DC Common Shares immediately prior to the DC Share Exchange. ...

Connections between 6(1)(a), 15(1) and 246(1) 39. No court has concluded on how to determine the value of a taxable benefit under subsection 246(1). ... However, as mentioned in the “Connections between 6(1)(a), 15(1) and 246(1)” section, case law that deals with the notion of “value of a benefit” under paragraph 6(1)(a) and subsection 15(1) can be used to determine the value of a benefit by virtue of subsection 246(1). ...