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You have advised that to the best of your knowledge, and that of the responsible officers of each of the taxpayers, none of the issues involved in this Ruling is: (i) in an earlier return of any of the taxpayers or a related person; (ii) being considered by a tax services office (TSO) or taxation centre (TC) 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 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. ... In connection with XXXXXXXXXX's acquisition of XXXXXXXXXX's common shares, as described in Paragraph 9, there was an amendment to the terms of the Debenture to remove the conversion feature. ...

XXXXXXXXXX 2006-020136 XXXXXXXXXX, 2007 Dear XXXXXXXXXX: Re: XXXXXXXXXX ("Subco") BN XXXXXXXXXX XXXXXXXXXX ("Parentco") XXXXXXXXXX (the "Project") XXXXXXXXXX ("A Co") XXXXXXXXXX ("X Entity") Advance Income Tax Ruling This is in reply to your letter dated XXXXXXXXXX, and further to your amending letter of XXXXXXXXXX, wherein you requested an advance income tax ruling in connection with the proposed transactions described below. ... You confirm that to the best of your knowledge, none of the issues involved in the ruling request is: (a) in an earlier return of any of Subco, Parentco, A Co or X Entity (collectively, the "Applicants") or a related person; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of any of the Applicants or a related person; (c) under objection by any of the Applicants or a related person; (d) the subject of a ruling previously considered by the Income Tax Rulings Directorate, with the exception of a related prior ruling regarding the tax-exempt status of XXXXXXXXXX ("B Group") and XXXXXXXXXX ("C Group"), and which is relevant to Ruling A, below; nor (e) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

Subco was created on the implementation of the Opco Plan to hold investments in connection with the Opco Plan. ... To the best of your knowledge, and that of the Corporate Group, any Member or any Participant, none of the issues involved in this Ruling are: (i) in an earlier tax return of any member of the Corporate Group, a Member or a Participant or any person related to a member of the Corporate Group, a Member or a Participant other than with respect to the operation of the deferred compensation plans as they presently exist; (ii) being or have been considered by a tax services office or tax centre in connection with a previously filed tax return of a member of the Corporate Group, a Member, a Participant or any person related to a member of the Corporate Group, a Member or a Participant; (iii) under objection by a member of the Corporate Group, a Member, a Participant or any person related to a member of the Corporate Group a member or a Participant; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; nor (v) the subject of a ruling previously issued by the Directorate to a member of the Corporate Group, a Member, a Participant or any person related to a member of the Corporate Group, a Member or a Participant other than as described in 8 of the above facts. ...

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) dealt with in an earlier return 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 the taxpayers or a related person; c) under objection by one or any 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 expired; and e) the subject of a ruling previously issued by this Directorate. ... In addition to the Fund's investment in Holdco Common Shares, the Fund also holds unsecured subordinated notes in the principal amount of $XXXXXXXXXX issued by Holdco (the "Holdco Notes") in connection with the transactions described in paragraph 11 below. ...

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. ... Either following the listing of the MFC Class A Shares referred to in paragraph 22 hereof or on the day following the day on which the election described in paragraph 22 hereof is filed, as the case maybe, and following the completion of the transactions described in paragraphs 24 and 25 hereof, XXXXXXXXXX and MFC (each of which is referred to as a "predecessor corporation" in the present paragraph) will undertake a vertical short-form amalgamation under the provisions of the XXXXXXXXXX to form Amalco-MFC in such a manner that: (a) all of the property (except any amounts receivable from any predecessor corporation or shares of the capital stock of any predecessor corporation) of the predecessor corporations held immediately before the amalgamation will become property of Amalco-MFC by virtue of the amalgamation; (b) all of the liabilities (except any amounts payable to any predecessor corporation) of the predecessor corporations immediately before the amalgamation will become liabilities of Amalco-MFC by virtue of the amalgamation; (c) all of the shares of XXXXXXXXXX held by MFC immediately prior to the amalgamation will be cancelled by virtue of the amalgamation; (d) in accordance with the provisions of the XXXXXXXXXX, the articles of amalgamation of Amalco-MFC will be the same as the articles of MFC, and Amalco-MFC will not issue any securities in connection with the amalgamation; and (e) the debt owing by XXXXXXXXXX to MFC as evidenced by the XXXXXXXXXX Notes will be deemed to be settled immediately prior to the amalgamation by a payment made by XXXXXXXXXX and received by MFC of an amount equal to MFC's cost amount of the XXXXXXXXXX Notes pursuant to subsection 80.01(3) of the Act. 27. ...

You have advised us that to the best of your knowledge and that of the taxpayer involved none of the issues involved in this ruling request are: (i) in an earlier return of the taxpayer or any related person; (ii) being considered by a tax services office (TSO) or taxation centre (TC) in connection with a previously filed tax return by the taxpayer or any related person; (iii) under objection by the taxpayers or any 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. ... In connection with the implementation of the Proposed Transactions certain existing indebtedness owing by DC (i.e. a line of credit owing to XXXXXXXXXX) will be restructured after the Proposed Transactions in order to ensure that DC does not violate the existing terms of such indebtedness as a result of the implementation of the Proposed Transactions. ...

XXXXXXXXXX 2004-007098 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request XXXXXXXXXX ("Opco") (XXXXXXXXXX) XXXXXXXXXX ("Sub 1") (XXXXXXXXXX) XXXXXXXXXX ("Sub 2") (XXXXXXXXXX) XXXXXXXXXX ("Sub 3") (XXXXXXXXXX) (collectively, the "Taxpayers") We are writing in response to your letter of XXXXXXXXXX in which you requested an advance income tax ruling on behalf of the Taxpayers and the Trust and AcquisitionCo, which are the entities that are to be created in connection with the Proposed Transactions described below. ... You have advised us that to the best of your knowledge, and that of the Taxpayers involved, none of the issues contained herein: (a) is in an earlier tax return of the Taxpayers or a related person; (b) is being considered by a tax services office or taxation center in connection with a previously filed tax return of the Taxpayers or a related person; (c) is under objection by the Taxpayers or a related person; (d) is before the Courts; and (e) is the subject of an advance income tax ruling previously issued by the Income Tax Rulings Directorate. ...

To the best of your knowledge and that of the taxpayers, none of the issues in this ruling 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. ... In connection with the winding-up of DC, DC will assign and distribute the Aco Note to Aco, the Bco Note to Bco, the Cco Note to Cco, the Dco Note to Dco and the Eco Note to Eco. ...

PRELIMINARY MATTERS To the best of your knowledge and that of the Taxpayers involved, none of the issues involved in this Ruling Request is: (a) dealt with in a previously filed return of the Taxpayers or a related person; (b) 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; (c) under objection by one or any of a Taxpayer or a related person; (d) before the courts or, if a judgment has been issued, the limit for appeal to a higher court has expired; or (e) the subject of a ruling previously considered by the Income Tax Rulings Directorate except to the extent that some of the issues and transactions are similar to ones in XXXXXXXXXX. ... 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-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; or (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. ...