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We acknowledge our telephone conversations in connection herewith. To the best of your knowledge, and that of the taxpayers named herein, none of the issues involved in this advance income tax ruling request is under objection or appeal or is being considered by any tax services office or taxation centre of Revenue Canada in connection with any income tax return already filed. ...

Dodd Acting Director General 957-3495 Att: Blair Chisholm Banking, Insurance and Financial Products 912991 This is in reply to your T2003 dated October 28, 1991 requesting our comments on the October 11, 1991 submission by XXX, on behalf of the Bank XXX in connection with certain of their securities transactions. ... Per the Australian High Court at p. 608: "... and the real thing that has to be decided is what were the acts that were done in connection with the business and whether they amount to a trading which would cause the profits that accrued to be profits arising from a trade or business...... ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in this ruling request is: (i) in a previously filed tax return of the taxpayers or persons related to the taxpayers; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or persons related to the taxpayers; (iii) under objection by the taxpayers or persons related to the taxpayers; (iv) the subject of a current or completed court process involving the taxpayers or persons related to the taxpayers; or (v) the subject of an advance income tax ruling previously issued by the Income Tax Rulings Directorate. ... For greater certainty, the Agreed Amount in respect of each such Eligible Property will be within the limits prescribed as follows: (a) in the case of Capital Property (other than Depreciable Property of a prescribed class) described in paragraph 85(1)(c.1), an amount equal to the lesser of the amounts described in subparagraphs 85(1)(c.1)(i) and (ii); (b) in the case of Depreciable Property of a prescribed class, an amount equal to the least of the amounts described in subparagraphs 85(1)(e)(i), (ii) and (iii); and (c) in the case of XXXXXXXXXX owned in connection with the XXXXXXXXXX carried on by DC, an amount determined in accordance with the formula set out in paragraph 85(1)(c.2). ...

Dodd Acting Director General 957-3495 Att: Blair Chisholm Banking, Insurance and Financial Products   912991 24(1) This is in reply to your T2003 dated October 28, 1991 requesting our comments on the October 11, 1991 submission by         24(1) on behalf of the Bank          24(1)          in connection with certain of their securities transactions. ... Per the Australian High Court at p. 608:      "... and the real thing that has to be decided is what were the acts that were done in connection with the business and whether they amount to a trading which would cause the profits that accrued to be profits arising from a trade or business...      ... ...

In connection with the XXXXXXXXXX estate freeze of Opco described above, BrotherACo, a taxable Canadian corporation incorporated under the XXXXXXXXXX, acquired XXXXXXXXXX% of the Class A shares (as hereafter defined) of BrotherA FamilyCo and XXXXXXXXXX % of the common shares of BrotherA FamilyCo. ... In connection with the XXXXXXXXXX estate freeze of Opco described above, BrotherBCo, a taxable Canadian corporation incorporated under the XXXXXXXXXX, acquired XXXXXXXXXX% of the Class A shares (as hereafter defined) of BrotherB FamilyCo and XXXXXXXXXX% of the common shares of BrotherB FamilyCo. ... In connection with the winding-up of Opco, Opco will distribute the AF Subco Note to BrotherA FamilyCo and the BF Subco Note to BrotherB FamilyCo. ...