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PRELIMINARY MATTERS To the best of your knowledge, and that of the responsible officers of the above-mentioned Taxpayers, none of the issues contained herein are: a) dealt with in a previously filed return of one of the Taxpayers or a related person; b) being considered by a tax services office or tax 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) the subject of a current or completed court process involving one of the Taxpayers or a related person; and e) the subject of a ruling previously considered 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, none of the proposed transactions and/or issues involved in this Ruling request are the same as or substantially similar to transactions or issues that are: (a) in a previously filed tax return of the Taxpayers or a related person and; (i) being considered by the CRA in connection with any such tax return; (ii) under objection by the Taxpayers or a related person; (iii) the subject of a current or completed court process involving the Taxpayers or a related person; or (b) the subject of a ruling request previously considered by the Income Tax Ruling Directorate in relation to the Taxpayers or a related person. ... The loans made to Holdco3 under this facility will be due on demand with no fixed terms of repayment; “New DC Common Shares” means the new class E common shares in the capital stock of DC to be authorized as part of the Proposed Transactions, as described in Paragraph 70; “New Holdco4” refers to a corporation to be incorporated as a part of the Proposed Transactions, as described in Paragraph 92; “New Holdco4 Common Shares” means the common shares in the capital stock of New Holdco4, as described in Paragraph 93; “NCL” means “non-capital loss” and has the meaning assigned by subsection 111(8); “NERDTOH” means “non-eligible refundable dividend tax on hand” as that term is defined in subsection 129(4); “PUC” means “paid-up capital” and has the meaning assigned by subsection 89(1); “Paragraph” refers to a numbered paragraph in this letter; “Predecessor Corporations” has the meaning assigned in Paragraph 96; “principal amount” has the meaning assigned by subsection 248(1); “proceeds of disposition” has the meaning assigned by section 54; “property” has the meaning assigned by subsection 248(1); “Property A” means a residential, revenue-producing rental property (XXXXXXXXXX suites) located at XXXXXXXXXX; “Property B” means a residential, revenue-producing rental property (XXXXXXXXXX suites) located at XXXXXXXXXX; “Property C” means a residential, revenue-producing rental property (XXXXXXXXXX suites) located at XXXXXXXXXX; “Property D” means a residential, revenue-producing rental property (XXXXXXXXXX suites) located at XXXXXXXXXX; “Property E” means a residential, revenue-producing rental property (XXXXXXXXXX suites) located at XXXXXXXXXX; “Property F” means a commercial property located at XXXXXXXXXX, which is used in connection with the operation of Property A, Property B, Property C, Property D and Property E; “Proposed Transactions” means the transactions described in Paragraphs 59 to 122 of this letter; “related” has the meaning assigned by section 251 as modified for the purposes of section 55 by paragraph 55(5)(e); “restricted financial institution” has the meaning assigned by subsection 248(1); “series of transactions or events” includes the transactions or events referred to in subsection 248(10); “Shareholder Loan 1” means the amount due from Holdco3 to Holdco1, that is unsecured, interest bearing, and due on demand with no fixed terms of repayment; “Shareholder Loan 2” means the amount due from Holdco3 to Holdco2, that is unsecured, interest bearing, and due on demand with no fixed terms of repayment; “Sibling 1” refers to XXXXXXXXXX of Sibling 2; “Sibling 2” refers to XXXXXXXXXX of Sibling 1; “significant influence” has the meaning assigned by section 3051.05 of the Accounting Standards for Private Enterprises; “specified financial institution” has the meaning assigned by subsection 248(1); “specified investment business” has the meaning assigned by subsection 125(7); “Spouse 1” refers to XXXXXXXXXX, spouse of Sibling 1; “Spouse 2” refers to XXXXXXXXXX, spouse of Sibling 2; “SPV1” means XXXXXXXXXX; “stated capital” means the amount included in the stated capital account attributable to a share of the capital stock of a corporation; “stated capital account” refers to an account that each corporation described in this letter is required to maintain for each class and series of its share capital, issued in accordance with Act1, and, in respect of each class and series of shares in the share capital of each such corporation, reflects the aggregate amount of the stated capital; “Subco1” refers to a corporation to be incorporated by Holdco1 as a part of the Proposed Transactions, as described in Paragraph 106; “Subco1 Common Shares” means the common shares in the capital stock of Subco1, as described in Paragraph 106; “Subco1 Redemption Note” means the non-interest bearing demand promissory note to be issued by Subco1 to DC2 on the redemption of its Subco1 Special Share owned by DC2, as described in Paragraph 113; “Subco1 Special Shares” means the preferred shares in the capital stock of Subco1, as described in Paragraph 106; “Subco2” refers to a corporation to be incorporated by Holdco2 as a part of the Proposed Transactions, as described in Paragraph 107; “Subco2 Common Shares” means the common shares in the capital stock of Subco2, as described in Paragraph 107; “Subco2 Redemption Note” means the non-interest bearing demand promissory note to be issued by Subco2 to DC2 on the redemption of its Subco2 Special Share owned by DC2, as described in Paragraph 114; “Subco2 Special Share” means the preferred shares in the capital stock of Subco2, as described in Paragraph 107; “substantial interest” has the meaning assigned by subsection 191(2); “suspended loss” means a loss to which subsection 40(3.4) applies; "TCC” means “taxable Canadian corporation” as that term is defined in subsection 89(1); “taxable dividend” has the meaning assigned by subsection 89(1); “taxable preferred shares” has the meaning assigned by subsection 248(1); “taxation year” has the meaning assigned by subsection 249(1); “TC” refers to a corporation to be incorporated as a part of the Proposed Transactions, as described in Paragraph 78; “TC Common Shares” means the common shares in the capital stock of TC, as described in Paragraph 79; “TC Redemption Note” means the non-interest bearing demand promissory note to be issued by TC to DC on the redemption of its TC Special Share owned by DC, as described in Paragraph 87; “TC Special Shares” means the preferred shares in the capital stock of TC, as described in Paragraph 79; “Trust 1” refers to the XXXXXXXXXX; “Trust 2” refers to the XXXXXXXXXX; “UCC” means “undepreciated capital cost” and has the meaning assigned by subsection 13(21); and “winding-up dividend” means the dividend arising on the winding-up of DC2 by virtue of subsection 84(2) and paragraph 88(2)(b), as described in Paragraphs 117 to 119, and Ruling F. ...