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You have advised us that to the best of your knowledge and that of the taxpayers involved none of the issues involved in this ruling is: (i) in an earlier return 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 the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (iv) the subject to a ruling previously issued by the Income Tax Rulings Directorate. ... For greater certainty, the Proposed Transactions described herein, in and by themselves, will not be considered to result in any disposition or increase in interest described in any of subparagraphs 55(3)(a)(i) to (v). ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in this ruling is: a. in an earlier 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 the taxpayers or a related person, c. under objection by the taxpayers or a related person, d. before the courts, or e. the subject of a ruling previously issued by this Directorate. ... The provisions of subsection 69(11) will not apply to the transfer of certain assets of BusinessA to PartnershipA as described in paragraph 27 above or to the transfer by XCO of its interest in PartnershipA to Aco as described in paragraph 42 above, unless there is a subsequent disposition (or arrangements are made for the subsequent disposition) of (i) the assets which are transferred to PartnershipA or (ii) the interest in PartnershipA or (iii) property substituted for property described in (i) or (ii), within 3 years after the transfers described in paragraphs 27 and 42 above and where it may reasonably be considered that one of the main purposes of the series of transactions or events (which includes the subsequent disposition of the assets, the interest in PartnershipA or properties substituted therefor) is to obtain a benefit of any item described in paragraphs 69(11)(a) or (b) which is available to a person (other than a person that is affiliated with XCO immediately before the series began). ...

Nothing in the Plan shall be considered as creating a trust or creating any fiduciary relationship. ... To the best of your knowledge and that of the Parent, the Corporation and the Employee, none of the issues involved in this ruling are: i) in an earlier return of the Corporation or the Employee, or any person related to the Corporation, the Employee or a Participant; ii) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Corporation, the Employee or a Participant, or any person related to the Corporation, the Employee or a Participant; iii) under objection by the Corporation, the Employee, a Participant, or any person related to the Corporation, the Employee or a Participant; iv) before the courts; nor v) the subject of an income tax ruling previously issued by CCRA to the Corporation, the Employer or a Participant. ...

To the best of your knowledge and that of Aco, none of the issues involved in this ruling request is: (i) involved 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. ... For greater certainty, the facts and proposed transactions described herein, in and by themselves, will not be considered to result in any disposition or increase in interest described in any of subparagraphs 55(3)(a)(i) to (v). ...

You have advised us that to the best of your knowledge and that of the taxpayers involved none of the issues involved in this ruling request are: (i) in an earlier return of the taxpayer 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 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 not expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... For the purposes of the Proposed Transactions, any tax accounts or other tax related amounts, such as loss carry-forwards, capital dividend account and refundable dividend tax on hand, will not be considered as property of DC. ...

You have advised us that to the best of your knowledge and that of the taxpayers involved none of the issues involved in this ruling request are: (i) in an earlier return of the taxpayers or related persons; (ii) being considered by a tax services office ("TSO") or taxation centre ("TC") in connection with a previously filed tax return of the taxpayers or related persons; (iii) under objection by the taxpayers or related persons; (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. ... In addition, (a) for the purpose of calculating the FMV of each type of property, as described above, DC will not have significant influence over any corporation; and (b) any tax accounts of DC, such as the amount of RDTOH account, the balance of any CDA, or any deferred income tax debit balance will not be considered property for purposes of the classification described herein. 24. ...

To the best of your knowledge and the knowledge of the taxpayers involved in the Proposed Transactions, none of the issues described in this ruling is: (a) in an earlier tax return of a taxpayer involved or a related person; (b) being considered by a tax services office or taxation centre in connection with any tax return previously filed by a taxpayer involved or a related person; (c) under objection or appeal by a taxpayer involved or a related person; (d) before the courts; or (e) the subject of a ruling previously issued to a taxpayer involved or a related person. ... For greater certainty, the Proposed Transactions described herein, in and by themselves, will not be considered to result in any disposition or increase in interest described in any of subparagraphs 55(3)(a)(i) to (v). ...

To the best of your and the Corporation's knowledge, none of the issues involved in this ruling are: (i) in an earlier return of the Corporation, a Participant, or any person related to the Corporation or a Participant; (ii) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Corporation, a Participant, or any person related to the Corporation or a Participant; (iii) under objection by the Corporation, a Participant, or any person related to the Corporation 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 the Corporation. ... Paragraph 7(3)(a) of the Act will apply where, as described in 13 above, an Executive enters into an XXXXXXXXXX with the Corporation in exchange for a release of any entitlement under the XXXXXXXXXX Plans such that, except as provided in section 7 of the Act as provided in C below, the Executive shall be considered to have neither received nor enjoyed any benefit as a result of entering into the XXXXXXXXXX or from acquiring Shares under the XXXXXXXXXX, to which subsection 5(1) or paragraphs 6(1)(a) or (i) of the Act would otherwise apply. ...

You have advised us that to the best of your knowledge and that of the taxpayers involved none of the issues involved in this ruling request are: (i) in an earlier return of the taxpayers or related persons; (ii) being considered by a tax services office ("TSO") or taxation centre ("TC") in connection with a previously filed tax return of the taxpayers or related persons; (iii) under objection by the taxpayers or related persons; (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. ... For the purposes of the proposed transactions, any tax accounts or other tax related amounts, such as loss carry-forwards, capital dividend account and refundable dividend tax on hand, will not be considered as property of DC. ...

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. ... Any amount of unpaid principal which the PLP owes on account of the Production Loans (the "Unpaid Loans") will be a limited-recourse amount of the PLP, with the result that: (i) the provisions of subsection 143.2(6) of the Act will apply to reduce the PLP's expenditures (including the amount of the Total NCLE) to the extent that the amount of the Unpaid Loans can reasonably be considered to relate to such expenditures incurred by the PLP; (ii) at the time that all or a portion of the Unpaid Loans are repaid by the PLP, the provisions of subsection 143.2(10) of the Act will apply to deem such expenditures to have been made or incurred at the time of, and to the extent of, the repayment; and (iii) the Unpaid Loans will not, in and of itself, result in the application of subsection 143.2(6) of the Act to reduce the cost of the Class A Units acquired by the MLP or the cost of the MLP Units acquired by the Investors. ...