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To the best of your knowledge and that of the Fund, none of the issues involved in this rulings request is: (a) in an earlier return of the Fund or a related person; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the Fund or a related person; (c) under objection by the Fund 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 Directorate, other than the Ruling issued XXXXXXXXXX, 2003 (ruling number 2003-0035913). ... Section XXXXXXXXXX states that Units of each Fund are not transferable, except as provided for in Sections XXXXXXXXXX, which are summarized as follows: (a) Section XXXXXXXXXX permits the transfer of Units to any person becoming entitled to said Units as a consequence of the death, incapacity, bankruptcy or insolvency of any Unitholder or otherwise by operation of law; (b) Section XXXXXXXXXX permits a transfer between plans that are registered plans permitted under the Act that are established for the benefit of the same Unitholder or the Unitholder's spouse; and (c) Section XXXXXXXXXX permits the transfer of Units to a transferee, pledgee, mortgagee or other encumbrancer for the purpose of granting or realizing on collateral or a security interest in a Unit in connection with a loan made to a Unitholder subject to certain conditions. 8. ... XXXXXXXXXX No Transfer of Units Units of each Fund are not transferable, except as provided for in Section XXXXXXXXXX hereof; XXXXXXXXXX Permitted Transfers Notwithstanding Section XXXXXXXXXX, upon the production of such agreements, instruments, certificates, opinions, documents or other records as the Trustee and the Manager may reasonably require and, with the written consent of the Manager, Units may be transferred: (a) to any person becoming entitled to any Units as a consequence of the death, incapacity, bankruptcy or insolvency of any Unitholder or otherwise by operation of law, provided that until any such transfer is recorded on the Register maintained by the Trustee, the Unitholder shall be deemed for all purposes to be the holder of the Units registered in its name and neither the Trustee nor the Manager shall be bound by or affected by any notice of such death, incapacity, bankruptcy or insolvency; (b) between such plan or plans registered under the Income Tax Act (Canada) as may be established by or for the benefit of the same Unitholder or their spouse; (c) to a transferee, pledgee, mortgagee or other encumbrancer for the purpose of granting or realizing on collateral or a security interest in such Units in connection with a loan made to a Unitholder, provided that such transferee, pledgee, mortgagee or other encumbrancer provides to the Manager and the Trustee such evidence as they may request to evidence such security interest or the right to realize upon such Units; or (d) to any other person, with the consent of the Manager. ...

We understand that, to the best of your knowledge and that of the taxpayer involved, none of the issues involved in the ruling request: (i) is in an earlier return of the taxpayer or a related person; (ii) is being considered by a tax services office or taxation center in connection with a previously filed tax return of the taxpayer or a related person; (iii) is under objection by the taxpayer or a related person; (iv) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (v) is the subject of a ruling previously considered by the Directorate. ... Aco does not act as a rental manager, contact or agent of the Owner in connection with the operation of the rental activities. 9. ... (d) Aco provides vacation rental software services to the Owner and facilitates the Owner's acquisition of an independent merchant number and facilitates the digital connection between a credit card payment and the Owner's software to record a payment and booking into the Owner's web site. ...

Principal Issues: 1)Withholding tax exemption on interest paid on a credit facility pursuant to 212(1)(b)(vii) 2)Reimbursement of expenses by the company to the Bank in connection with the negotiation, preparation, conclusion and implementation of the agreement. ... To the best of your knowledge and that of the above noted company, none of the issues or matters involved in this advance income tax ruling request have been or are being considered by a District Taxation Office and/or Taxation Centre in connection with a tax return already filed or is under objection and/or appeal. ... If such an event of default occurs, XXXXXXXXXX shall be entitled by written notice to XXXXXXXXXX, to terminate the Agreement and/or to declare the amount then outstanding due and payable. 14.All costs and expenses of any kind arising in connection with the negotiation, preparation, conclusion and implementation of the Agreement, and/or security agreement, and/or any other agreement pertaining hereto shall be exclusively borne by XXXXXXXXXX. ...

We understand that, to the best of your knowledge and that of the taxpayer, none of the issues involved in the Ruling request: (i) is in an earlier return of the Company or a related person; (ii) is being considered by a Tax Services Office or Taxation Centre in connection with a previously filed tax return of the Company or a related person; (iii) is under objection by the Company or a related person; (iv) is before the courts; or (v) is the subject of a Ruling previously issued by this Directorate to the Company or a related person. ... No prospectus or offering memorandum will be prepared in connection with any such issuance of units and, under applicable securities laws, no such prospectus or offering memorandum will be required to be delivered to an Investor or delivered to or filed with any securities regulatory body in Canada. 7. ... The Fund will not incur any cost in connection with such guarantee. 13. ...

To the best of your knowledge and that of the Fund, none of the issues involved in this rulings request is: (a) in an earlier return of the Fund or a related person; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the Fund or a related person; (c) under objection by the Fund 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 Directorate. ... Section XXXXXXXXXX states that Units of each Fund are not transferable, except as provided for in Sections XXXXXXXXXX, which are summarized as follows: (a) Section XXXXXXXXXX permits the transfer of Units to any person becoming entitled to said Units as a consequence of the death, incapacity, bankruptcy or insolvency of any Unitholder or otherwise by operation of law; (b) Section XXXXXXXXXX permits a transfer between plans that are registered plans permitted under the Income Tax Act (Canada) that are established for the benefit of the same Unitholder or the Unitholder's spouse; (c) Section XXXXXXXXXX permits the transfer of Units to a transferee, pledgee, mortgagee or other encumbrancer for the purpose of granting or realizing on collateral or a security interest in a Unit in connection with a loan made to a Unitholder subject to certain conditions. 8. ... Notwithstanding Section XXXXXXXXXX, upon the production of such agreements, instruments, certificates, opinions, documents or other records as the Trustee and the Manager may reasonably require and, with the written consent of the Manager, Units may be transferred: (a) to any person becoming entitled to any Units as a consequence of the death, incapacity, bankruptcy or insolvency of any Unitholder or otherwise by operation of law, provided that until any such transfer is recorded on the Register maintained by the Trustee, the Unitholder shall be deemed for all purposes to be the holder of the Units registered in its name and neither the Trustee nor the Manager shall be bound by or affected by any notice of such death, incapacity, bankruptcy or insolvency; (b) between such plan or plans registered under the Income Tax Act (Canada) as may be established by or for the benefit of the same Unitholder or their spouse; (c) to a transferee, pledgee, mortgagee or other encumbrancer for the purpose of granting or realizing on collateral or a security interest in such Units in connection with a loan made to a Unitholder, provided that such transferee, pledgee, mortgagee or other encumbrancer provides the Trustee such evidence as the Trustee may request to evidence such security interest or the right to realize upon such Units; or (d) to any other person, with the consent of the Trustee. 11. ...

The company has adopted a policy of declaring bonuses to its principal shareholder/manager to remunerate him for the profits the company has earned that are attributable to his special know-how, connections and entrepreneurial skill. ... We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in the ruling request: (i) is in an earlier return of a taxpayer or a related person; (ii) is being considered by a Tax Services Office or Taxation Centre in connection with a previously filed tax return of a taxpayer or a related person; (iii) is under objection by a taxpayer or a related person; (iv) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; and (v) is the subject of a ruling previously issued by the Directorate. ... The Corporation's profits since inception have stemmed from the Shareholder/Manager's special knowledge, skills and connections in the Business. 11. ...

We also acknowledge the information provided in subsequent correspondence and during our various telephone conversations in connection with your request. We understand that, to the best of your knowledge and that of the Company, the issues involved in the ruling request are not: a) in an earlier return of the Company, the Shareholders or a person related to the Company or the Shareholders; b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the Company, the Shareholders or a person related to the Company or the Shareholders; c) under objection by the Company, the Shareholders or a person related to the Company or the Shareholders; d) before the courts, or the subject of a judgment to which the time limit for appeal to a higher court has not expired; or e) the subject of a ruling previously considered by the Income Tax Rulings Directorate. ... Subsection 56(2) will not apply to require that any Shareholder include any amount in its income in connection with the proposed transactions. ...

We also acknowledge the information provided in subsequent correspondence and during our various telephone conversations in connection with your request XXXXXXXXXX. We understand that to the best of your knowledge and that of the taxpayers involved: i) none of the issues involved in the requested ruling is being considered by any District Tax Services Office or Taxation Centre of the Agency in connection with a tax return already filed, and ii) none of the issues involved in the requested ruling is the subject of any notice of objection or is under appeal. ... COMMENTS Except as expressly stated herein, nothing in this ruling should be construed as implying that the Canada Customs and Revenue Agency has accepted, approved or confirmed any income tax implications in connection with the facts or proposed transactions referred to herein. ...

We also acknowledge the information provided in subsequent correspondence in connection with your request (XXXXXXXXXX). We understand that, to the best of your knowledge and that of the taxpayer involved, none of the issues involved in the Ruling request is: (a) in a previously filed tax return of the taxpayer or a related person; (b) being considered by the CRA in connection with such return of the taxpayer or a related person; (c) under objection by the taxpayer or a related person; (d) the subject of a current or completed court process involving the taxpayer or a related person; or (e) the subject of a Ruling previously considered by the Directorate. ... An invoice for our fees in connection with this ruling will be forwarded to you under separate cover. ...

PARENT and OPCO will jointly elect, in prescribed form and within the time permitted, under section 85 in connection with this transfer and the elected amount will be nominal. 29. ... PARENT and OPCO will jointly elect, in prescribed form and within the time permitted, under section 85 in connection with the transfer. ... PARENT and OPCO will jointly elect, in prescribed form and within the time permitted, under section 85 in connection with this transfer. ...