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We understand that to the best of your knowledge and that of the taxpayers on whose behalf this ruling was requested, none of the issues involved in this ruling are: (a) in an earlier return of the taxpayers referred to above 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 taxpayers referred to above or a related person; (c) under objection by the taxpayers referred to above or a related person; (d) in relation to the taxpayers referred to above or a related person, before the courts or the subject of a judgment the time limit for appeal from which has not expired; or (e) the subject of a ruling previously considered by the Income Tax Rulings Directorate in relation to the taxpayers referred to above or a related person. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

We also took into consideration the additional information provided in your letter dated XXXXXXXXXX, and the email correspondence we have exchanged between XXXXXXXXXX PRELIMINARY MATTERS: To the best of your knowledge, none of the issues involved in this Ruling Request: (a) is in an earlier return of Opco, or a related person; (b) is being considered by a tax services office or a taxation centre in connection with a previously filed tax return of Opco or a related person; (c) is under objection by Opco or a related person; (d) is before the Courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; and (e) is the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... The general position of the CRA with respect to price adjustment clauses is stated in Interpretation Bulletin IT-169 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 issues described herein is: (i) dealt with in an earlier tax return of any of the taxpayers or any 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 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 not 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. ...

We understand that, to the best of your knowledge and that of the taxpayer, none of the issues described herein are: i) in an earlier tax return of the Fund 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 Fund or a related person; iii) under objection by the Fund or a related person; iv) the subject of a ruling previously issued by the Income Tax Rulings Directorate of the Canada Revenue Agency ("CRA") to the Fund or a related person, or; v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired. ... In accordance with the provisions of the BCA, the articles of amalgamation of Amalco MFC will be the same as the articles of incorporation of MFC, and Amalco MFC will not issue any securities in connection with the amalgamation described in paragraph 16 above. 18. ...

We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling request herein are: (i) dealt with in an earlier return of B Co or a related person; (ii) being considered by a Tax Services Office or a Taxation Centre in connection with an income tax return previously filed by B Co or a related person; (iii) under objection by B Co or a related person; (iv) the subject of a previous ruling issued by the Income Tax Rulings Directorate to B Co or a related person other than 2003-002803, dated XXXXXXXXXX, 2003, and as amended by supplementary advance income tax ruling 2003-004699, dated XXXXXXXXXX, 2003 (collectively, the "Prior Ruling"); nor (v) before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has expired. ... The purposes of the Trust, as expressed in its Declaration of Trust, will include, inter alia, (i) to act as tenant of B Co, as landlord, under the Concurrent XXXXXXXXXX Lease and to act as sublandlord to D Co and Z Co, as co-subtenants, under the XXXXXXXXXX Lease, (ii) to act as tenant of B Co, as landlord, under the Concurrent XXXXXXXXXX Lease and to act as sublandlord to D Co, as subtenant, under the XXXXXXXXXX Lease, (iii) to acquire the XXXXXXXXXX Promissory Note and the XXXXXXXXXX Promissory Note, (iv) to acquire such other securities, indebtedness and other financial instruments as the Trustee of the Trust considers advisable and in the best interests of the Trust in connection with the purposes described in (i), (ii), and (iii) above, and (v) to borrow funds for the purposes of transacting any or all of the foregoing activities. 26. ...

We understand that, to the best of your knowledge, and that of the taxpayers involved, none of the issues described herein is: (i) in an earlier return of the Partnership, any of the Partners or a related person; (ii) being considered by a Tax Services Office or Taxation Centre in connection with a previously filed return of the Partnership, any of the Partners or a related person; (iii) the subject of any notice of objection; (iv) before the courts or, if a judgment has been issued, the time limit for appeal has not expired; or (v) the subject of a previously issued ruling. ... None of the associates are Partners in the Partnership or are the subject of the Proposed Transactions; (d) "associated" when used in connection with a Professional Corporation or Contracting Company has the meaning described in subsection 256(1) of the Act; (e) "Building" means the building located at XXXXXXXXXX, being the location where XXXXXXXXXX carries on the Practice; (f) "Building Owner" means an individual, corporation or trust which owns a co- venture ownership interest in the Building; (g) "Building Owners' Agreement" means the agreement entered into among the Building Owners as may be amended from time to time which governs the terms of ownership for the Building; (h) "Business Names Act" means XXXXXXXXXX XXXXXXXXXX (i) "Canadian-controlled private corporation" or "CCPC" has the meaning assigned by subsection 125(7) of the Act; (j) "City" means the City of XXXXXXXXXX; (k) "Contracting Company" means each Professional Corporation that will be incorporated as permitted under the laws of the Province (and as described in Paragraph 7) for the benefit of an existing Principal and that will be engaged by the Partnership to provide Professional Services and collectively, they are referred to as "Contracting Companies"; (l) "Corporations Act" means XXXXXXXXXX; (m) "Cost Sharer" means in respect of a particular period: (i) each person who was a Partner at any time during such period, (ii) any Associate who is required in such period to contribute either directly or through a Non-Electing Partner to the expenses of XXXXXXXXXX and (iii) any person other than a Principal who in such period is engaged by a Contracting Company and who utilizes XXXXXXXXXX resources for which a fee is charged under a Supply Agreement to such Contracting Company; (n) "CRA" means the Canada Revenue Agency; (o) "Disability" means a physical or mental disability which prevents a Partner from performing his or her responsibilities to the Partnership for the applicable period of time specified under the terms of Partnership and "Disabled" has a corresponding meaning; (p) "Distributable Professional Services Income" means in respect of any Non Electing Partner for a particular fiscal year, an amount equal to XXXXXXXXXX for that Partner in such fiscal year; (q) "Electing Partners" means those Partners who elect, and are approved by the Management Committee, to provide Professional Services to the Partnership through a Contracting Company, as more particularly described in Paragraph 8; (r) "Equity Partner" means a Partner of XXXXXXXXXX who: (i) has the right to vote on any matter that comes before the Partnership; (ii) owns an interest in the Plant; and (iii) has the right to receive income and the obligation to pay Shared Expenses in accordance with the terms of the Partnership Agreement; (s) "Expense Unit" means in respect of any particular period, the aggregate of the following: (i) in respect of each Full Cost Sharer, 1 and (ii) in respect of each Partial Cost Sharer, an amount equal to the portion of the Shared Expenses determined by the Partnership to be payable by the Partial Cost Sharer in such period; and "Expense Units" means the aggregate of the foregoing for that particular period; (t) "XXXXXXXXXX " and "Partnership" are used interchangeably and each means the partnership which currently carries on the Practice under XXXXXXXXXX XXXXXXXXXX, a registered Limited Liability Partnership pursuant to the laws of the Province; (u) "Fiscal Year" means the fiscal year of the Partnership, being XXXXXXXXXX XXXXXXXXXX; (v) "Full Cost Sharer" means in respect of a particular period, a Cost Sharer who in accordance with the policies of XXXXXXXXXX is responsible for a Full Share of Shared Expenses for such particular period; (w) "Full Share of Shared Expenses" means: Shared Expenses for a particular period Number of Expense Units in such period (x) XXXXXXXXXX (y) "XXXXXXXXXX " means an individual who holds a valid certificate from the XXXXXXXXXX to practice XXXXXXXXXX in the Province; (z) XXXXXXXXXX (aa) "Limited Liability Partnership" means a partnership formed pursuant to the Partnership Act and registered under the Business Names Act as a limited liability partnership; (bb) "Management Committee" shall mean the management committee of the Partnership, as more particularly described in subparagraph 4(i); (cc) "Named Partner" means XXXXXXXXXX XXXXXXXXXX. ...

You have advised that to the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (a) in an earlier tax return of one of the taxpayers or any related person; (b) being considered by a tax services office or taxation 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) 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 Income Tax Rulings Directorate. ... In connection with each liquidation and dissolution, all of the property of each TC will be distributed to its Shareholders and such Shareholder will assume the liabilities of its TC (other than liabilities owing to such Shareholder that are extinguished as a result of the dissolution), including its TC Note. 25. ...

We understand that, to the best of your knowledge, and that of the taxpayers involved, none of the issues described herein is: (i) in an earlier return of the Partnership, any of the Partners or a related person; (ii) being considered by a Tax Services Office or Taxation Centre in connection with a previously filed return of the Partnership, any of the Partners or a related person; (iii) the subject of any notice of objection; (iv) before the courts or, if a judgment has been issued, the time limit for appeal has not expired; or (v) the subject of a previously issued ruling. ... They include, among other things: (i) promoting, and contributing to the growth of, the Practice, (ii) conducting management functions, (iii) educating Professionals and staff, (iv) enhancing the Partnership's profile, (v) recruitment and (vi) referrals; (c) "associated" when used in connection with a Professional Corporation or a Contracting Company has the meaning described in subsection 256(1) of the Act; (d) "Canadian-controlled private corporation" has the meaning assigned by subsection 125(7) of the Act; (e) "Contracting Company" means each Professional Corporation that will be incorporated as permitted under the laws of the Province (and as described in Paragraph 11) for the benefit of an existing Principal and that will be engaged by the Partnership to provide Professional Services and, collectively, they are referred to as "Contracting Companies"; (f) "Corporations Act" means the XXXXXXXXXX (g) "CRA" means the Canada Revenue Agency; (h) "Electing Partners" means those Partners who elect to provide Professional Services to the Partnership through a Contracting Company, as more particularly described in Paragraphs 9 and 12. ...

To the best of your knowledge and that of the Taxpayers, none of the issues involved in the 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 a tax centre in connection with a tax return already filed by 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, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or v. except as set out in Ruling 2015-060144, the subject of a ruling previously issued by the Directorate to any of the Taxpayers or a related person. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

We also acknowledge the information provided in subsequent correspondence in connection with your request. We understand that, to the best of your knowledge and that of the taxpayer involved, none of the issues involved in this 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; or (iv) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...