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We also acknowledge the information provided in subsequent correspondence and during our various telephone conversations in connection with your request. ... is being considered by a Tax Services Office or Taxation Centre in connection with a previously filed tax return of a taxpayer named herein or a related person;? ... No fractional Aco Share will be issued in connection with this exchange and any fraction of XXXXXXXXXX or greater will be rounded up to a whole Aco share and any fraction of less than XXXXXXXXXX will be cancelled. 17. ...

We acknowledge the letters of XXXXXXXXXX and the information provided during our various telephone conversations in connection with your request. We understand that to the best of your knowledge and that of the taxpayers involved, none of the issues discussed in this ruling request is: (a) in an earlier return of the taxpayers or a related person; (b) being considered by a Tax Services Office or a 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) subject to a ruling previously issued by the Income Tax Rulings Directorate to the taxpayers or a related person; or (e) before the courts. ... In connection with the winding-up of Subco2, all of the property of Subco2 will be distributed to TC and TC will assume all of the liabilities of Subco2, including the amount owing to DC under the Subco2 Note. 21. ...

To the best of your knowledge and that of XXXXXXXXXX none of the issues involved in this ruling is being considered by a Tax Service Office or Taxation Centre in connection with any tax return already filed and, further, none of the issues involved is the subject of any notice of objection or is under appeal. ... XXXXXXXXXX was formed as a limited partnership on XXXXXXXXXX under the XXXXXXXXXX in connection with the reorganization (the "XXXXXXXXXX Reorganization") of XXXXXXXXXX (collectively, the "Predecessor Partnerships"). ... The interests of XXXXXXXXXX and the XXXXXXXXXX Estate may be exchanged at any time for units of XXXXXXXXXX at the same exchange ratios used in connection with the XXXXXXXXXX Reorganization (i.e. ...

XXXXXXXXXX To the best of your knowledge and that of the taxpayers involved, none of the issues involved in this ruling: i) is in an earlier return of the taxpayer(s) 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 taxpayer(s) or a related person; iii) is under objection by the taxpayer(s) 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 Revenue Canada or the Canada Customs and Revenue Agency. ... In connection with the rulings provided in paragraphs F and G above, except as set out below in Opinion numbers 2 to 4, XXXXXXXXXX, all as described above in paragraph 14 will not, in and of themselves, result in the application of paragraphs 96(2.2)(c) or (d) of the Act to reduce the at-risk amount of an Investor in respect of the MLP, or the at-risk amount of the MLP in respect of the PLP.. ... Subject to the application of subsections 18(9) and (9.2) to (9.8) of the Act, interest paid in a taxation year or payable in respect of a taxation year by an Investor (depending upon the method regularly followed by an Investor in computing income) in connection with their Investment Loan will be deductible in computing income in that taxation year in accordance with paragraph 20(1)(c) of the Act, to the extent that the amount thereof is reasonable and paid pursuant to a legal obligation to pay interest on borrowed money used for the purpose of earning income from a business or property with a reasonable expectation of profit. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained 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) subject to a ruling previously issued by the Income Tax Rulings Directorate; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ... The employee who had been employed as the full-time custodian/superintendent of property #4 was terminated and E, J and X ceased performing full-time employment duties and began to perform part-time employment duties in connection with properties #1, 2, 3, 5 and 6 immediately after the end of Opco's XXXXXXXXXX taxation year. ... In connection with the winding-up, Opco will distribute to Asub, Bsub and Csub, respectively, the Asub Note, the Bsub Note and the Csub Note. ...

To the best of your knowledge and that of the parties involved none of the issues contained in this letter: is in an earlier income tax return of the taxpayers or a related person; is being considered by a Tax Services Office or Taxation Centre in connection with a tax return already filed; is under objection by the taxpayers or a related person; or is before the Courts. ... Other than shares of farm co-operatives which it holds in connection with its farming business, the Distributing Corporation will not, prior to undertaking the transactions described below, own shares of any other corporation. 17. ... In respect of the transfer described in the paragraph 31 above, the Distributing Corporation and the Transferee Subsidiary, as the case may be, will jointly elect pursuant to subsection 85(1), in prescribed form and within the time limits prescribed by subsection 85(6), to transfer each asset that is an eligible property, within the meaning of subsection 85(1.1), and that has a FMV in excess of its cost amount to the Distributing Corporation, at an agreed amount that is not less than: (a) the least of the amounts specified in subparagraphs 85(1)(d)(i), (ii) or (iii) in the case of eligible capital property; (b) the least of the amounts specified in subparagraphs 85(1)(e)(i), (ii) or (iii) in the case of depreciable property of a prescribed class; (c) the lesser of the amounts specified in subparagraphs 85(1)(c. 1)(i) or (ii) in the case of capital property (other than depreciable property of a prescribed class), inventory, NISA Fund No. 2, or any other property described in paragraph 85(1)(c. 1); and (d) the amount specified in paragraph 85(l)(c.2) in respect of inventory owned in connection with the carrying on of a business the income from which is calculated on the cash basis and, for greater certainty, this will apply to inventories utilized in the farming business. ...

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 taxpayers involved, none of the issues involved in the 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 an advance income tax ruling previously issued by the 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 are the same as or substantially similar to transactions and/or issues that are: i. in a previously filed return of the Taxpayers or a related person and; A. 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; B. under objection by the Taxpayers or a related person; C. the subject of a current or completed court process involving the Taxpayers or a related person; or ii. the subject of a ruling previously considered by the Income Tax Rulings Directorate in relation to the Taxpayers or a related person. ... Specifically, the agreed amount under such election in respect of each eligible property so transferred will be within the limits prescribed as follows: a) in the case of depreciable property of a prescribed class, an amount equal to the least of the amounts specified in subparagraphs 85(1)(e)(i), (ii) and (iii); b) in the case of property described in paragraph 85(1)(c.1), an amount equal to the lesser of the amounts specified in subparagraphs 85(1)(c.1)(i) and (ii), and c) in the case of farm inventory owned in connection with the farming business carried on by DC, an amount determined in accordance with the formula set out in paragraph 85(1)(c.2). ... 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, and that of the responsible officers of the above-noted taxpayers, none of the proposed transactions 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 any of the above-noted taxpayers or a related person and: i. being considered by the CRA in connection with such return; ii. under objection by any of the above-noted taxpayers or a related person; or iii. the subject of a current or completed court process involving any of the above-noted taxpayers or a related person; or (b) the subject of a ruling request previously considered by the Income Tax Rulings Directorate. ... As consideration for the property transferred by DC to TC1 and TC2, each of TC1 and TC2, as the case may be, will issue a number of TC Special Shares to DC which will have an aggregate redemption amount and aggregate FMV equal to the aggregate FMV of such transferred property received by TC1 or TC2, as the case may be, in connection with the transfer. 29. ... 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 matters considered in this ruling request are: a) in an earlier return of the taxpayers or related persons; b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the taxpayers or related persons; c) under objection by the taxpayers or related persons; d) before the courts; or e) the subject of a ruling previously issued by this Directorate to the taxpayers or related persons. ... Subs and GPco 1; (ttt) "Trust Distributable Cash" means all amounts received by the Trust during any period after satisfaction of its interest obligations, if any, and less among other things, amounts that may be paid by the Trust in connection with any repurchases of Trust Units, amounts which the Trust Trustee may reasonably consider necessary to provide for payment of any costs and expenses required for operation of the Trust and amounts for any principal repayments and reserves for any principal repayments in respect of the Trust Notes; (uuu) "Trust Note Indenture" means the trust indenture, dated XXXXXXXXXX, entered into between the Trust and the Note Trustee providing for the issuance of the Trust Notes; (vvv) "Trust Notes" means Series 1 Trust Notes, Series 2 Trust Notes and Series 3 Trust Notes collectively, issued pursuant to the Trust Note Indenture and having the following characteristics: (A) redeemable at any time at the option of the Trust prior to maturity; (B) principal and interest is subordinated to the prior payment in full of the principal and accrued interest on, and all other amounts owing in respect of, all senior indebtedness; and (C) not convertible into or exchangeable for, or provide a holder with, any right to acquire property that is foreign property; (www) "Trust Unit" means a trust unit of the Trust, each such unit representing an equal undivided beneficial interest therein; (xxx) "Trust Unitholder" means a holder of Trust Units; (yyy) "Trust Trustees" means, at a time, an individual or a corporation that is at that time a trustee of the Trust; (zzz) XXXXXXXXXX; and (aaaa) "unit trust" has the meaning assigned by subsection 108(2). ... Pursuant to the terms of the Fund Declaration of Trust, the Fund's operations and activities shall be restricted to: a. investing in securities including those issued by the Trust; b. temporarily holding cash in interest bearing accounts, short-term government debt or investment grade corporate debt for the purposes of paying the expenses of the Fund, paying amounts payable by the Fund in connection with the redemption of any Fund Units and making distributions to Fund Unitholders; c. issuing units or securities convertible into Fund Units; d. issuing debt securities or borrowing funds and pledging securities held by the Fund or any affiliate as security for such debt securities or borrowed funds; e. issuing rights and Fund Units under any unitholder rights plan adopted by the Fund; f. purchasing securities under any issuer bid made by the Fund or pursuant to this Declaration of Trust; g. lending money to the Trust; and h. undertaking such other activities or taking such actions, including investing in securities, as contemplated under this Declaration of Trust or as shall be approved by the Fund Trustees from time to time, provided that the Fund shall not undertake any activities, take any action, or make any investment which would result in the Fund not being considered a "mutual fund trust" for purposes of the Act. 8. ...