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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 Aco, Dco, or a related person; (ii) being considered by a tax services office or a taxation centre in connection with a tax return already filed by Aco, Dco, or a related person; (iii) under objection by Aco, Dco, or a related person; (iv) the subject of a previous ruling issued by the Income Tax Rulings Directorate to Aco, Dco, or a related person; nor (v) before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

The comments in this paper on stock options, stock dividends, and stock splits should also be considered. ...

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 persons related to the taxpayer; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or persons related to the taxpayer; (iii) under objection by the taxpayer or persons related to the taxpayer; (iv) before the courts; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

To the best of your knowledge and that of the taxpayers, none of the issues involved in this advance income tax ruling is: (i) dealt with in an earlier return of the taxpayers or a person related to the taxpayers; (ii) being considered by any tax services office or taxation centre in connection with a tax return previously filed by the taxpayers or a person related to the taxpayers; (iii) under objection by the taxpayers or by a person related to the taxpayers; (iv) the subject of a previously issued ruling by the Income Tax Rulings Directorate; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

To the best of your knowledge and that of the parties identified above, none of the issues raised in this ruling request are (a) in an earlier return of any of the parties 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 parties or a related person, (c) under objection by any of the parties 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 issued to any of the parties or a related person by the Income Tax Rulings Directorate of the Canada Revenue Agency. ...

To the best of your knowledge, and that of the Corporation, SisterCo, SubCo, Partnership 1 and Partnership 2 none of the issues in this ruling request is: (i) involved in an earlier return of the Corporation, SisterCo, SubCo, Partnership 1, Partnership 2 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 Corporation, SisterCo, SubCo or a related person; (iii) under objection by the Corporation, SisterCo, SubCo or a related person; (iv) before the courts; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate of the Canada Revenue Agency, to the Corporation, SisterCo, SubCo, Partnership 1, Partnership 2 or related persons. ...

We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in the ruling request: (i) is in an earlier return of the taxpayers 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 taxpayers or a related person; (iii) is under objection by the taxpayers 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; or (v) is the subject of a ruling previously issued by the Directorate. ...

For the purpose of applying Article X of the Convention, the amount of a dividend referred to in Ruling A or B will be considered to be income as described in the definition "dividends" in Article X(3) of the Convention that is derived by US Holdco. ...

The address and business number of the various companies in the affiliated group described herein are as follows: Name Address Business Number Holdco XXXXXXXXXX XXXXXXXXXX Opco 1 XXXXXXXXXX XXXXXXXXXX Opco 2 XXXXXXXXXX XXXXXXXXXX Opco 3 XXXXXXXXXX XXXXXXXXXX Lossco 1 XXXXXXXXXX To be determined (New corporation) Lossco 2 XXXXXXXXXX To be determined (New corporation) Newco XXXXXXXXXX To be determined (New corporation) 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 is: (i) dealt with in an earlier return of Holdco, Opco 1, Opco 2, Lossco 1, Lossco 2, Newco or a related person; (ii) being considered by a tax services office or a taxation centre in connection with a tax return already filed by Holdco, Opco 1, Opco 2, Lossco 1, Lossco 2, Newco or a related person; (iii) under objection by Holdco, Opco 1, Opco 2, Lossco 1, Lossco 2, Newco or a related person; (iv) the subject of a previous ruling issued by the Income Tax Rulings Directorate to the taxpayers or a related person; nor, (v) before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

Other Information Other than as outlined in 13 and 14 above, to the best of your knowledge and that of Canco, none of the issues involved in this advance income tax ruling is: in an earlier return of Canco or a related person; being considered or under assessment by a tax services office or taxation centre in connection with a previously filed tax return of Canco or a related person; under objection by Canco or a related person; before the courts, and no judgement has been issued which may be under appeal; or the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...