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To the best of your knowledge and that of the above-referenced taxpayers, none of the issues raised in this letter is: (i) in an earlier income tax return of the above-referenced taxpayer or a person related to that taxpayer; (ii) being considered by a tax services office or a taxation centre in connection with a previously filed tax return of the above-referenced taxpayer or a person related to that taxpayer; (iii) under objection by the above-referenced taxpayer or a person related to that taxpayer; (iv) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

We understand that to the best of your knowledge and that of the taxpayers involved, none of the issues described herein is: (i) dealt with in an earlier return of the taxpayers or a related person, (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or a related person, (iii) under objection by 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. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

We understand that to the best of your knowledge and that of the taxpayers on whose behalf this ruling is being requested, none of the issues involved in this ruling request is: (a) in an earlier return of any of the taxpayers or a related person; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of any of the taxpayers or a related person; (c) under objection by any of the taxpayers or a related person; (d) the subject of a ruling previously issued by the Income Tax Rulings Directorate; or (e) except as described herein, before the Courts. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

You have advised us that to the best of your knowledge, and that of the Taxpayer, none of the issues contained herein is: (a) in an earlier return of the Taxpayer or any related person; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the Taxpayer or any related person; (c) under objection by the Taxpayer or any related person; (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; or (e) the subject of a ruling previously considered by the Directorate. ... In connection with the exchange, (a) the DC Common Shares so exchanged will be cancelled; (b) the aggregate addition to the stated capital in respect of the DC New Common Shares and the DC Butterfly Shares issued by DC on the exchange described in this Paragraph will not exceed the paid-up capital of the DC Common Shares (excluding any DC Common Shares owned by the Dissenting Shareholders) immediately before the exchange. ...

We understand that to the best of your knowledge and that of the taxpayers involved, none of the issues described herein is: (i) dealt with in an earlier tax return of any of the taxpayers or any related person; (ii) being considered by a Tax Services Office or Taxation Centre in connection with a previously filed tax return 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 not expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

PRELIMINARY MATTERS To the best of your knowledge, none of the issues involved in this Ruling Request: (a) is in an earlier return of DC, or a related person; (b) is being considered by a tax services office or a taxation centre in connection with a previously filed tax return of DC or a related person; (c) is under objection by DC or a related person; is before the Courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; and (d) is the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... 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 (a) in an earlier tax return of one of the taxpayers or any related person; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of one of the taxpayers or a related person; (c) under objection by one of the taxpayers or a related person; (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (e) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... The Proposed Transactions were not contemplated, planned or implemented in connection with XXXXXXXXXX death. 4.2 Cousinco 3 is a CCPC and a TCC. ...

You have advised us that to the best of your knowledge and that of the taxpayers involved none of the issues involved in this ruling request are: (i) in an earlier return of the taxpayer 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 the taxpayers or a related person; (iii) under objection by 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. ... Distributing acquired all of the XXXXXXXXXX Shares in connection with the incorporation of Forco1 in XXXXXXXXXX. ...

In this regard, we acknowledge your written submissions of XXXXXXXXXX made in connection with your request, our numerous telephone conversations with respect thereto XXXXXXXXXX You have advised us that to the best of your knowledge, and that of the Taxpayers, none of the issues contained herein is: (a) in an earlier return of a Taxpayer or a person related to a Taxpayer; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of a Taxpayer or a person related to a Taxpayer; (c) under objection by a Taxpayer or a person related to a Taxpayer; (d) the subject of a ruling previously issued by the Income Tax Rulings Directorate; or (e) before the Courts. ...

You have advised us that to the best of your knowledge and that of the taxpayer involved none of the issues involved in this ruling request are: (i) in an earlier return of any of the taxpayer 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 taxpayer or a related person; (iii) under objection by any of the taxpayer 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. ... DC has obligations under certain options (collectively the "Existing DC Broker Options" and individually an "Existing DC Broker Option"), whereby in connection with certain previous equity financing transactions, certain brokers involved in such equity financing became entitled to acquire Existing DC Shares at specified exercise prices. ...