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We understand that, to the best of your knowledge, and that of the taxpayers on whose behalf this ruling is requested, none of the issues contained in this advance income tax ruling are: (a) contained in earlier returns of the taxpayers or a related person; (b) being considered by a tax services office and/or a tax centre in connection with a tax return previously filed by the taxpayers or a related person; (c) under objection by the taxpayers or related person; (d) before the courts; or (e) the subject of a ruling previously issued by the Directorate to the taxpayers or a related person. ...

PAYMENTS TO A FORMER PARTNER IN RESPECT OF GOODWILL AND WORK IN PROGRESS Work in progress and goodwill, like other properties of a partnership, are considered to be owned by the partnership for tax purposes. ...

To the best of your knowledge, and that of the taxpayers named herein, none of the issues involved in the ruling requested in this letter is in any return of the taxpayers or related persons; is being considered by a tax services office or taxation centre in connection with a previously filed tax return of any of the taxpayers or related persons; is under objection by any of the taxpayers or related persons; is before the courts; or is the subject of a ruling relative to the taxpayers previously issued by the Directorate. ...

We understand that to the best of your knowledge and that of each of the Taxpayers involved, none of the proposed transactions and/or issues involved in this ruling are the same as, or substantially similar to, transactions and/or issues that are: a. in a previously filed tax return of the Taxpayers or person related to the Taxpayers; b. being considered by the CRA in connection with a previously filed tax return of the Taxpayers or a person related to the Taxpayers; c. under objection by the Taxpayers or a person related to the Taxpayers; 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 an advance income tax ruling previously issued by the Income Tax Rulings Directorate of the CRA in connection with the Taxpayers or a person related to the Taxpayers. ...

To the best of your knowledge, and that of any of the taxpayers, 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. ... (c) certain matters relating to their conduct after the implementation of the proposed transactions, including: (i) XXXXXXXXXX; (ii) the terms and conditions for implementing the $XXXXXXXXXX charitable giving described in Paragraph 50 above, including the terms and conditions for carrying out the charitable commitments made by Aco prior to the implementation of the proposed transactions; (iii) the ownership and disposition of assets received by the Siblings' Holdcos and assets retained by Aco on the proposed transactions, including restrictions on dispositions, co-ownership agreements and property management agreements in respect of the Real Properties, and shareholders agreements in respect of XXXXXXXXXX; and (iv) the resignation of directors of Aco and releases for such directors; (d) finalize and submit an application for this ruling as soon as possible; (e) negotiate and enter into a memorandum of understanding which would reflect the terms and conditions of the term sheet, while an application for this ruling is being considered by the Agency; (f) implement the proposed transactions as soon as possible after the receipt of this ruling; (g) certain changes to the proposed transactions in certain events, such as the death or mental or physical incapacity of Father. ... While the application for this ruling was being considered by the Agency, Aco, Father, the Siblings, the Family Trusts and the Holdcos decided not to negotiate and enter into a memorandum of understanding to reflect the terms and conditions of the term sheet referred to in Paragraph 55 above and instead will go directly to negotiating and entering into the documents to implement the proposed transactions and the documents referred to in Paragraph 77 below. ...

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 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 or a related person; (iii) under objection by Aco, or a related person; (iv) the subject of a ruling previously issued by the Income Tax Rulings Directorate to Aco 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. ...

To the best of your knowledge, and that of the taxpayer involved, none of the issues involved in this ruling request is: (i) dealt with in a return of the above-referenced taxpayer 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 above-referenced taxpayer or a related person; (iii) under objection by the above-referenced taxpayer 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 of the CRA. ...

You have advised us that to the best of your knowledge, and that of the Taxpayers, none of the issues contained herein is: (a) in an earlier return of a Taxpayer or a person related to a Taxpayer; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of a Taxpayer or a person related to a Taxpayer; (c) under objection by a Taxpayer or a person related to a Taxpayer; (d) the subject of a ruling (other than the XXXXXXXXXX 2005 Ruling and the Existing Ruling) previously issued by the Income Tax Rulings Directorate; or (e) before the Courts. ...

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 a Canadian Subsidiary 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 a Canadian Subsidiary or a related person, (c) under objection by any of a Canadian Subsidiary 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 a Canadian Subsidiary or a related person by the Income Tax Rulings Directorate of the CRA. ...

The DC Subco common shares and the DC Subco Promissory Note will be considered as cash for all purposes hereof and will be distributed to the parties as cash in the implementation of the transactions described herein. ...