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To the best of your knowledge and that of the taxpayers, none of the issues in this ruling request is: (i) in an earlier return of any 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 any of the taxpayers or a related person; (iii) under objection by any of the taxpayers or a related person; (iv) before the courts; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... Pursuant to the amalgamation agreement: (a) all of the property (except amounts receivable from any predecessor corporation or shares of the capital stock of any predecessor corporation) of the predecessor corporations immediately before the merger will become property of Mergeco by virtue of the merger; (b) all of the liabilities (except amounts payable to any predecessor corporation) of the predecessor corporations immediately before the merger will become liabilities of Mergeco by virtue of the merger; (c) the shares of Opco will be cancelled without any repayment of capital in respect of those shares; and (d) the shares of Holdco will not be cancelled on the merger and no shares of the capital stock of Mergeco will be issued by Mergeco in connection with the amalgamation. ... Pursuant to the amalgamation agreement: (a) all of the property (except amounts receivable from any predecessor corporation or shares of the capital stock of any predecessor corporation) of the predecessor corporations immediately before the merger will become property of New Dco by virtue of the merger; (b) all of the liabilities (except amounts payable to any predecessor corporation) of the predecessor corporations immediately before the merger will become liabilities of New Dco by virtue of the merger; (c) the shares of Dco2 will be cancelled without any repayment of capital in respect of those shares; and (d) the shares of Dco will not be cancelled on the merger and no shares of the capital stock of New Dco will be issued by New Dco in connection with the amalgamation. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in this advance ruling is: (i) dealt with in an earlier return of the taxpayer 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 taxpayer or a related person, (iii) under objection by 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 not expired, or (v) is the subject of a ruling previously issued by this Directorate. ... These warrants were issued in connection with a financing undertaken by DC in XXXXXXXXXX, are exercisable at $XXXXXXXXXX per warrant and will expire on or before XXXXXXXXXX. ... 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. ...

You have represented to us that, to the best of your knowledge, none of the issues involved in this ruling request are: (i) dealt with in a previously filed information or tax return of any of the Taxpayers or of a related person or partnership; (ii) being considered by a tax services office or a tax centre in connection with a previously filed tax return of any of the Taxpayers or of 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 expired; or (v) the subject of a ruling previously considered by the Income Tax Rulings Directorate in connection with any of the Taxpayers or a related person. ... An invoice for our fees in connection with this ruling request will be sent to you under separate cover. ...

We also acknowledge the information provided in various e-mails correspondence and during various telephone conversations in connection with your ruling request (XXXXXXXXXX). 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. ...

You have advised that to the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein are: (a) in previously filed return of the taxpayer 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 taxpayer or a related person; (c) under objection by the taxpayer 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 expired; or (e) the subject of a ruling previously considered by the Income Tax Rulings Directorate. ... In connection with the winding-up of DC, DC will assign and distribute the TC1 Redemption Note to TC1, the TC2 Redemption Note to TC2 and the TC3 Redemption Note to TC3. ... 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 taxpayers, none of the issues involved in the ruling request is: (i) in previously filed tax returns of the taxpayers or a related person; (ii) being considered by a tax services office or a tax centre in connection with previously filed tax returns of the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) the subject of a current or completed court process involving any of the taxpayers or a related person; or (v) the subject of a ruling previously considered by the Directorate. ... The REIT also has issued “Special Voting Units” which are owned exclusively by holders of exchangeable partnership interests issued by subsidiary partnerships of the REIT in connection with certain completed acquisitions, and which entitle the holders thereof to vote together with the holders of REIT Units. ... In connection with the termination of Finance Trust, the REIT will assume any liabilities of Finance Trust not otherwise provided for (including, for greater certainty, any obligations of Finance Trust to pay Dissenting Unitholders the fair value of their former Finance Trust Units under the Finance Trust Declaration of Trust and any obligations of Finance Trust for previously declared, but unpaid, cash distributions to Finance Trust Unitholders). ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein: (i) is in an earlier return of the taxpayers 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 taxpayers or a related person; (iii) is under objection by the taxpayers or a related person; and (iv) is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ... On XXXXXXXXXX one Class XXXXXXXXXX Voting share was issued to DC in connection with the organization of New Subco. 16. ... On XXXXXXXXXX one Class XXXXXXXXXX Voting share was issued to DC in connection with the organization of Newco. ...

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. ... In connection with the winding-up, the ACo2 Redemption Note will be assigned and distributed to ACo1, the BCo2 Redemption Note will be assigned and distributed to BCo1 and the CCo2 Redemption Note will be assigned and distributed to CCo1. 46. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

You advise that to the best of your knowledge and that of XXXXXXXXXX, none of the issues involved in the ruling request has been considered by a taxation services office or a taxation centre in connection with a tax return already filed, and none of the issues involved in the ruling request is the subject of any notice of objection or is under appeal. ... The Subco A Shares will be issued for $XXXXXXXXXX per share. 26.XXXXXXXXXX will then sell the XXXXXXXXXX separate classes of Subco A Shares to XXXXXXXXXX for a sale price of $XXXXXXXXXX per share XXXXXXXXXX. 27.Subco A will use the proceeds of the subscription referred to in paragraph 25 above to repay the Daylight loan referred to in paragraph 24. 28.XXXXXXXXXX will agree to make payments to Subco A as contributions of capital to provide Subco A with sufficient funds to meet Subco A's required dividend payments on the Subco A Shares, and any fees and expenses incurred by Subco A in connection with the transactions described herein. ... The Subco B Shares will be issued for $XXXXXXXXXX per share. 41.Subco B will use the proceeds of the subscription referred to in paragraph 40 above to repay the XXXXXXXXXX loan referred to in paragraph 39 above. 42.XXXXXXXXXX will agree to make payments to Subco B as contributions of capital to provide Subco B with sufficient funds to meet Subco B's required dividend payments on the Subco B Shares, and any fees and expenses incurred by Subco B in connection with the transactions described in paragraphs 38 and 39 above. ...

You have advised that, to the best of your knowledge and that of the taxpayers, none of the issues involved in the ruling request is: (i) in previously filed tax returns of the taxpayers or a related person; (ii) being considered by a tax services office or a tax centre in connection with previously filed tax returns of the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) the subject of a current or completed court process involving any of the taxpayers or a related person; or (v) the subject of a ruling previously considered by the Directorate, other than Ruling XXXXXXXXXX issued to you on XXXXXXXXXX in respect of the same taxpayers. ... The REIT also has issued “Special Voting Units” which are owned exclusively by holders of exchangeable partnership interests issued by subsidiary partnerships of the REIT in connection with certain completed acquisitions, and which entitle the holders thereof to vote together with the holders of REIT Units. ... In connection with the termination of Finance Trust, the REIT will assume any liabilities of Finance Trust not otherwise provided for (including, for greater certainty, any obligations of Finance Trust to pay Dissenting Unitholders the fair value of their former Finance Trust Units under the Finance Trust Declaration of Trust and any obligations of Finance Trust for previously declared, but unpaid, cash distributions to Finance Trust Unitholders). ...