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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 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 expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... For greater certainty, the Proposed Transactions, in and by themselves, will not be considered to result in any disposition or increase in interest described in subparagraphs 55(3)(a)(i) to (v). ... To the extent that Distributing can trace XXXXXXXXXX to its acquisition of the XXXXXXXXXX, Distributing will be considered to have used XXXXXXXXXX to repay XXXXXXXXXX on the repayment of such loan as described in Paragraph 69 within the meaning of subsection 20(3), and therefore, to the extent of such tracing, will be deemed to have used XXXXXXXXXX for the same purposes as XXXXXXXXXX was used. ...

You have advised that to the best of your knowledge, and that of all the taxpayers involved, none of the issues raised in this letter are being considered by any Tax Service Office ("TSO") and/or Taxation Centre in connection with any tax return already filed by the taxpayers, nor are any of these issues under objection or appeal. ... As noted above, XXXXXXXXXX 8.XXXXXXXXXX, under the Act such entities are considered to be related, and consequently, they are deemed not to deal with each other at arm's length. ... "Adverse Yield Event" means: (i)any new legislation or any change in any applicable existing or new legislation (and for these purposes "legislation" shall include any order-in-council, regulation, rule, guideline, treaty or directive, whether or not having the force of law) of Canada or any province of Canada (other than any such change which results in a change in any rate of tax, including surtax, applicable to financial institutions or corporations generally), any announcement by any governmental authority, entity or agency (including any central bank or other fiscal or monetary authority or agency) of Canada or any province of Canada regarding the enactment of such new legislation or the making of any such change, any change in the interpretation or administration of any applicable legislation by any governmental authority, entity or agency (including any central bank or other fiscal or monetary authority or agency) of Canada or any province of Canada, or any notice from Revenue Canada that the income tax ruling in respect of these transactions has ceased to be applicable in accordance with its terms for any reason whatsoever; (ii)any judgment or order of a court of competent jurisdiction in Canada or any province of Canada in any matter or case, whether or not an appeal has been instituted and notwithstanding the existence of any right of appeal; (iii)any change in the status of XXXXXXXXXX, as the case may be, (including, without limitation, the loss of its status as a taxable Canadian corporation) under any applicable legislation of Canada or any province of Canada; (iv)any request or direction (whether or not having the force of law) from any authority, entity or agency (including any central bank or other fiscal or monetary authority of agency) in Canada or any province of Canada; (v)any assessment or reassessment of any person for any Canadian federal or provincial tax or both, which, in the sole opinion of any holder of XXXXXXXXXX, as the case may be, has, or may reasonably be expected to have, one or more of the following effects: (vi) requiring such holder, in computing its income subject to tax, to include the amount of any dividends or other distribution, or any part thereof received or receivable or deemed to be received or receivable by such holder, or accrued and unpaid (whether or not declared or set aside) on any of the XXXXXXXXXX, as the case may be, held by such holder, and precluding such holder, in computing its taxable income, from deducting an amount equal to such amount; (vii)precluding such holder, in computing its income subject to tax, from deducting any amount paid or payable on account of interest on any indebtedness or on account of costs and expenses incurred, or considered by the relevant taxing authority to have been incurred, by such holder in connection with, or arising directly or indirectly as a result of, its acquisition or holding or both of any of the XXXXXXXXXX, as the case may be; (viii)imposing upon such holder any tax (other than income tax on any amount described in (vi) and (vii) above), or levying any penalty of other charge, or on in respect of any redemption proceeds or any dividend or other distribution or any part thereof received or receivable or deemed to be received or receivable by such holder, or accrued and unpaid (whether or not declared or set aside), on any of the XXXXXXXXXX, as the case may be, held by such holder or otherwise on or in respect of the acquisition, holding or disposition (excluding any income or capital gains tax in respect of an actual gain on disposition) of any of the XXXXXXXXXX, as the case may be, or any combination of the foregoing; (ix)(A)imposing, modifying or deeming applicable any reserve, liquidity, cash margin, special deposit, deposit insurance or similar requirement against assets held by, or deposits in or for the account of, or in respect of any acquisition of funds or loan by, a Canadian office of such holder; or (B)imposing on such holder, or expecting there to be maintained by such holder, any capital adequacy or additional capital requirement (including without limitation, a requirement that affects such holder's allocation of capital resources to its obligations) in connection with the assets or obligations; and the result of any of the foregoing is to increase the cost to such holder or reduce the income receivable, or the effective return on capital or assets realizable, by such holder with respect to or in connection with any of the XXXXXXXXXX, as the case may be, held by such holder, or to cause such holder to make any payment or forego any interest, fees, dividends, distributions or other return on, or calculated by reference to, any sum received or receivable in connection with any of the XXXXXXXXXX, as the case may be, held by such holder; (x) increasing the after-tax cost by any amount to such holder of holding any of the XXXXXXXXXX, as the case may be, or otherwise decreasing the after-tax return to such holder on any of the XXXXXXXXXX, as the case may be, held by such holder by any amount; (xi)imposing upon such holder any interest, penalty or other charge in respect of any amounts described in subparagraphs (vi), (vii), (viii), (ix) or (x) above; or (xii)making it unlawful or impossible for such holder to continue to hold any of the XXXXXXXXXX, as the case may be, held by such holder or to give effect to its obligations under the transaction documents relating to the issuance and holding of the XXXXXXXXXX, as the case may be; provided that, for the purpose of subparagraphs (vi), (vii), (viii), (x) and (xi) above, it is to be assumed that: (A)the holder referred to therein is, at all relevant times and throughout all relevant periods both taxable and paying tax at the highest Canadian federal corporate tax rate (including federal surtaxes) and the greatest of the maximum rates of provincial corporate tax rate applicable in any province of Canada (including provincial surtaxes) at such times and throughout such periods; and (B)such holder has, as its sole assets, the XXXXXXXXXX, as the case may be, held by it and has revenues, costs and expenses relating only to such XXXXXXXXXX, as the case may be. ...

We understand that 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 a taxpayer identified in this document or of a related person, (ii) is being considered by any Tax Services Office or Taxation Centre of the Agency in connection with a tax return already filed, (iii) is under objection by a taxpayer identified in this document or by 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 considered by this Directorate. ... A Secured Creditor which is a non-resident of Canada will not be considered not to deal at arm's length with New Debtor or Amalco solely by reason of the rights and the New Instruments acquired by the Secured Creditors pursuant to the Plan. ...

To the best of your knowledge and that of the Applicants involved, none of the issues contained herein: (i) is in an earlier tax return of any of the Applicants 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 any of the Applicants or a related person; (iii) is under objection by any Applicant or a related person; (iv) is before the Courts or, if a judgement has been issued, the time limit for appeal to a higher Court has expired; or (v) is the subject of an advance income tax ruling previously issued by the Income Tax Rulings Directorate XXXXXXXXXX. ... The terms and conditions described in 19(a) above of the Class A shares, the transfer of the Class A shares by LP C, LP D and LP E to Mutual Fund Co as described in 11 and 38 above, the rights to receive payments under the PPA described in 7 above XXXXXXXXXX will not, in and by themselves, result in the Class A shares issued by Opco to LP C, LD D, LP E or LP F as described above being considered taxable preferred shares or short-term preferred shares for purposes of the Act. ... Provided that the Class A shares qualify as XXXXXXXXXX, the Class A shares issued as described above will not be considered tax shelters within the meaning assigned by subsection 237.1(1) of the Act. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in this ruling request is (i) in an earlier return of one 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 one of the taxpayers or a related person; (iii) under objection by one 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. ... For greater certainty, any tax accounts, such as the balance of any non-capital losses and net capital losses will not be considered property in determining the net fair market value of the property of CCo for the purposes of the Proposed Transactions. ... For greater certainty, any tax accounts, such as the balance of any non-capital losses and net capital losses will not be considered property in determining the net fair market value of the property of BCo for the purposes of the Proposed Transactions. ...

You have confirmed that to the best of the knowledge of the Offering Partnership, the Production Services Partnership, the Production Co. and XXXXXXXXXX, none of the issues contained herein: a) is in an earlier return of the General Partner, the Initial Limited Partner, PSGP, the Production Co. or a related person; b) is being considered by a tax services office or taxation centre in connection with previously filed return of the General Partner, the Initial Limited Partner, PSGP, the Production Co. or a related person; c) is under objection by the General Partner, the Initial Limited Partner, PSGP, the Production Co. 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 not expired; or e) is the subject of a ruling previously issued by the Canada Customs and Revenue Agency. ... Any amount of unpaid principal which the Production Services Partnership owes to PSGP under the Interim Production Loan will be a limited-recourse amount, as defined in subsection 143.2(1) of the Act, of the Production Services Partnership with the result that: (i) the provisions of subsection 143.2(6) of the Act will apply to reduce the Production Services Partnership's expenditures (including the amounts of the NCLE) to the extent that the amount of the Interim Production Loan can reasonably be considered to relate to such expenditures incurred by the Production Services Partnership; (ii) at the time that all or a portion of the Interim Production Loan is repaid by the Production Services Partnership, 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 payment, provided such repayment is not part of a series of loans or other indebtedness and repayments; and (iii) the Interim Production Loan 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 Offering Partnership or the cost of the Units in the Offering Partnership acquired by the Investors. ... Any amount owing by the Offering Partnership to: (i) the Production Services Partnership in respect of the unpaid portion of the subscription price in respect of Class A Units of the Production Services Partnership; and (ii) XXXXXXXXXX as described in 28 above, will be a limited recourse amount, as defined in subsection 143.2(1) of the Act, of the Offering Partnership with the result that: (i) the provisions of subsection 143.2(6) of the Act will apply to reduce the Offering Partnership's expenditures to the extent that the amount of such outstanding amounts can reasonably be considered to relate to such expenditures incurred by the Offering Partnership; (ii) at the time that all or a portion of the outstanding amounts are repaid by the Offering Partnership, 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 payments, provided such repayment is not part of a series of loans or other indebtedness and repayments; and (iii) the amount owing to the Production Services Partnership in respect of the Class A Units and the amount owing to XXXXXXXXXX referred to in 28 above will not, in and of itself, result in the application of subsection 143.2(6) of the Act to reduce the cost of the Units in the Offering Partnership acquired by the Investors. ...

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 (the "CCRA"). ... If an interest in the Production Services Partnership constitutes a tax shelter investment, within the meaning of subsection 143.2(1) of the Act, then by virtue of the application of subsection 143.2(8) of the Act, any amount of unpaid principal which the Production Services Partnership owes to XXXXXXXXXX under the Interim Production Loan or the Short-term Loan will be a limited-recourse amount, as defined in subsection 143.2(1) of the Act, of the Production Services Partnership with the result that: (i) the provisions of subsection 143.2(6) of the Act will apply to reduce the Production Services Partnership's expenditures (including the amounts of the NCLE) to the extent that the amount of the Interim Production Loan or the Short-term Loan can reasonably be considered to relate to such expenditures incurred by the Production Services Partnership; (ii) at the time that all or a portion of the Interim Production Loan, or the Short-term Loan, is repaid by the Production Services Partnership, 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 payment, provided such repayment is not part of a series of loans or other indebtedness and repayments; and (iii) the Interim Production Loan and the Short-term Loan will not, in and of themselves, result in the application of subsection 143.2(6) of the Act to reduce the cost of the Class A Units acquired by the Offering Partnership or the cost of the Units in the Offering Partnership acquired by the Investors. ... If an interest in the Offering Partnership constitutes a tax shelter investment, within the meaning of subsection 143.2(1) of the Act, then by virtue of the application of subsection 143.2(8) of the Act, any amount owing by the Offering Partnership to the Production Services Partnership in respect of the unpaid portion of the subscription price in respect of Class A Units of the Production Services Partnership will be a limited-recourse amount, as defined in subsection 143.2(1) of the Act, of the Offering Partnership with the result that: the provisions of subsection 143.2(6) of the Act will apply to reduce the Offering Partnership's expenditures to the extent that the amount of such outstanding amounts can reasonably be considered to relate to such expenditures incurred by the Offering Partnership; at the time that all or a portion of the outstanding amounts are repaid by the Offering Partnership, 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 payments, provided such repayment is not part of a series of loans or other indebtedness and repayments; and the amount owing to the Production Services Partnership in respect of the Class A Units will not, in and of itself, result in the application of subsection 143.2(6) of the Act to reduce the cost of the Units in the Offering Partnership acquired by the Investors. ...

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 & Interpretations Directorate; or (v) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ... For greater certainty, any tax accounts, such as the balance of any non-capital losses, investment tax credits, RDTOH or CDA of Amalco, will not be considered property for purposes of the proposed transactions described herein. 12. ... Nothing in this letter should be interpreted as confirming that, (a) for purposes of the Act, any adjustment made pursuant to any such price adjustment clause in respect of a transaction subsequent to the time of such transaction will be effective, retroactively, to the time of such transaction, (b) for the purposes of the Act, any amount paid pursuant to any such price adjustment clause, in respect of a transaction subsequent to the time of such transaction will be an additional payment of the redemption or purchase price of any shares redeemed or repurchased; or (c) in the event that any adjustment is made pursuant to any such price adjustment clause, the proposed transactions referred to above will be considered to have been carried out as described herein, in particular, for the purposes of the ruling C above The operation of a price adjustment clause is not a proposed transaction and, consequently, advance rulings are not given by the Department in respect thereof. ...

You have advised that to the best of your knowledge and that of the taxpayers involved none of the issues involved in this ruling request: (a) is involved in an earlier return of the taxpayers or a related person, (b) is being considered by a tax services office or taxation centre in connection with a tax return already filed by the taxpayers or a related person, (c) is under objection, (d) is before the courts or, if a judgement has been issued, the time limit for appeal has not expired, and (e) is the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... The principal amount owing to Amalco by Holdco under the Holdco Note, as described in 23 above, will be set off against a portion of the principal amount owing to Holdco by Amalco (formerly Aco) under the Aco Note, as described in 18 above, and the Holdco Note will be cancelled and considered to be paid in full. ... For greater certainty, the proposed transactions described above, in and by themselves, will not be considered to result in any disposition of property 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 Proposed Transactions (as defined below) or the issues involved in this Ruling request are the same as or substantially similar to transactions or issues that are: (i) in a previously filed tax return of any of the Taxpayers or a related person and: A. being considered by the CRA in connection with such return; B. under objection by any of the Taxpayers or a related person; or C. the subject of a current or completed court process involving any of the Taxpayers or a related person; or (ii) the subject of a Ruling request previously considered by the Income Tax Rulings Directorate. ... For greater certainty, the Proposed Transactions described herein, in and of themselves, will not be considered to result in any disposition or significant increase in interest described in subparagraphs 55(3)(a)(i) to (v). ...