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We understand that, to the best of your knowledge, and that of the taxpayers involved, none of the issues described herein is: (i) in an earlier return of any of the taxpayers or related persons; (ii) being considered by a Tax Services Office or Taxation Centre in connection with a previously filed return of any of the taxpayers or a related person; (iii) the subject of any notice of objection; (iv) before the courts or, if a judgment has been issued, the time limit for appeal has not expired; or (v) the subject of a previously issued ruling. ... Provided that the Named Partner providing XXXXXXXXXX Services to Partnership G through the Particular Contracting Company would not, but for the existence of the Particular Contracting Company, reasonably be regarded as an officer or employee of Partnership G in respect of those services, then the Particular Contracting Company will not be considered to be carrying on a personal services business. ...

We understand that to the best of your knowledge, and that of the Applicants (as herein defined), as of the date of the initial request for the income tax rulings given herein, being XXXXXXXXXX, none of the issues contained herein: (a) was dealt with in an earlier return of ParentCo1 or ParentCo2, or any person related thereto; or (b) was being considered by a tax services office or taxation centre in connection with a tax return of ParentCo1 or ParentCo2, or any person related thereto; and as of the date hereof, none of the issues contained herein: (c) is under objection by Amalco1 or ParentCo2, or any related person; (d) is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired; or (e) is the subject of a ruling previously considered by the Directorate. ...

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 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. ... For greater certainty, the Proposed Transactions described herein, in and by themselves, will not be considered to result in a disposition or increase in interest described in subparagraphs 55(3)(a)(i) to (v) with respect to the dividends deemed to be received by Holdco or Newco described in Ruling B. ...

To the best of your knowledge and that of the Taxpayer, none of the issues involved in the ruling request is: i. in an earlier return of the Taxpayer or a related person; ii. being considered by a tax services office or a tax centre in connection with a tax return already filed by the Taxpayer or a related person; iii. under objection by the 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 not expired; and v. the subject of a ruling previously issued by the Directorate to the Taxpayer or a related person. ... Our understanding of the facts, the proposed transactions and the purpose of the proposed transactions is as follows: Definitions (a) "Account" means an account to be maintained by the Trustees in respect of each Participant; (b) "Applicable Law" means any applicable provision of law, domestic or foreign, including, without limitation, the Securities Act (XXXXXXXXXX) as amended, together with all regulations, rules, policy statements, rulings, notices, orders or other instruments promulgated thereunder and any applicable Stock Exchange Rules; (c) "Beneficiary" means any person designated by a Participant by written instrument filed with the Corporation to receive any amount, securities or property payable under the Plan in the event of a Participant's death or, failing any such effective designation, the Participant's estate; (d) "Board" means the Board of Directors of the Corporation; (e) "Committee" means the XXXXXXXXXX or any other committee of the Board, as constituted from time to time, which may be appointed by the Board to, inter alia, interpret, administer and implement the Plan; (f) "Contribution" means any contributions which may be made by the Corporation to the Trust pursuant to the terms of the Plan; (g) "Corporation" means the Taxpayer and its successors and assigns; (h) "CRA" means the Canada Revenue Agency; (i) "FMV" means fair market value, being that amount at which property would be transferred by a willing buyer to a willing seller, in an open and unrestricted market, between informed parties under no compulsion to act, as would be determined in accordance with the basic principles of valuation endorsed by the Canadian Institute of Chartered Business Valuators; (j) "Incentive Bonus" means any incentive bonus which is declared by the Corporation in respect of a Participant pursuant to the provisions of the Plan, as described in paragraph 10 below; (k) "Independent Broker" means the independent broker appointed by the Trustees to advise on and execute purchases of Shares for the Plan, on the basis described in paragraph 13 below; (l) "Notice of Award" means a signed, written agreement between a Participant and the Corporation evidencing the terms and conditions under which an Incentive Bonus has been declared under the Plan; (m) "Parent" means the XXXXXXXXXX and its successors and assigns, which corporation owns indirectly XXXXXXXXXX% of the issued and outstanding shares of the Corporation; (n) "Participant" means a permanent employee of the Corporation who has been designated by the Corporation for participation in the Plan and who has agreed to participate in the Plan; (o) "Plan" means the Corporation's proposed bonus plan which is the subject of this ruling request; (p) "Shares" means the common shares in the capital of the Parent as presently constituted or any shares in the capital of the Parent into which such shares are changed, reclassified, subdivided, consolidated or converted or which is substituted for such shares, or as such shares may further be changed, reclassified, subdivided, consolidated, converted or substituted, which shares are currently listed on the XXXXXXXXXX Stock Exchange and trade under the symbol XXXXXXXXXX; (q) "Share Unit" means a unit credited by means of an entry to a Participant's Account pursuant to the Plan, which represents the right of the Participant to receive an equivalent number of fully paid Shares, at the time, in the manner, and subject to the terms, set forth in the Plan; and (r) "Stock Exchange Rules" means the applicable rules of any stock exchange upon which Shares of the Parent are listed, as amended; (s) "Termination Date" means the date on which a Participant ceases, for any reason, to be an employee of the Corporation or an affiliate thereof, provided that a termination of employment shall be deemed not to occur by reason of a transfer of the Participant between the Corporation to an affiliate thereof, and further provided that the Participant's employment shall not be considered terminated while the Participant is on short-term or long-term disability or a leave of absence from the Corporation or an affiliate which is approved by the Corporation; (t) "Trust" means the XXXXXXXXXX Employee Benefit Plan Trust proposed to be settled by the Corporation in connection with the Plan; (u) "Trustees" means the individuals appointed to be Trustees of the Trust; and the following terms from the Act are also used: (v) "ACB" or "adjusted cost base" as defined by section 54 of the Act; (w) "arm's length" as defined by subsection 251(1) of the Act; (x) "employee benefit plan" as defined in subsection 248(1) of the Act; (y) "salary deferral arrangement" as defined in subsection 248(1) of the Act; (x) "taxable Canadian corporation" as defined by subsection 89(1) of the Act; Facts 1. ...

We understand that to the best of your knowledge and that of Partnership and Named Partner (collectively the "Taxpayers"), none of the issues involved in the 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 a tax centre in connection with a tax return already filed by 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 not expired; and v. the subject of a ruling previously issued by the Directorate to one of the Taxpayers or a related person. ... Provided that the Named Partner providing XXXXXXXXXX Services to the Partnership through the Particular Contracting Company would not, but for the existence of the Particular Contracting Company, reasonably be regarded as an officer or employee of the Partnership in respect of those services, then the Particular Contracting Company will not be considered to be carrying on a personal services business. ...

We understand that (i) the present ruling request is intended to be supplemental to the advance income tax ruling given to the Entity on XXXXXXXXXX, 2006 (our file number 2005-013900) (the "Previous Ruling"), and that to the best of your knowledge and that of the taxpayer, none of the issues involved in the ruling request is: (ii) in an earlier return of the taxpayer or a related person, (iii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or a related person, (iv) under objection by the taxpayer or a related person, or (v) before the courts. ... For purposes of XXXXXXXXXX law, the Entity is considered a not for profit organization and exempt from income tax in XXXXXXXXXX. 2. ...

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. ... Based on the respective fair market value of each beneficiary's interest in the Estate, Beneficiary 1 would be considered to control the deemed corporation represented by the Estate pursuant to clause 88(1)(c.2)(ii)(B) at all times that she or Beneficiary 2 acquire property acquired by Amalco on the amalgamation referred to in Paragraph 9 or property acquired by any person in substitution therefor. ...

To the best of your knowledge and that of the above-referenced taxpayer, none of the issues involved in this ruling request is: (i) in an earlier 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 (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 best of your knowledge, and that of the taxpayers, none of the issues contained in this ruling request is: (a) in a previously filed 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 the taxpayers or a related person; (d) the subject of a current or completed court process involving the taxpayers or a related person; or (e) the subject of a ruling request previously considered by the Directorate. ...

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 expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... For the purposes of subparagraph 111(5)(a)(ii) of the Act, the income of Lossco which will be derived from the leasing or rental of the Office Equipment Assets, which assets will be transferred to Lossco as described in paragraph 15 above, will be considered to be derived from properties similar to those leased or rented by Lossco in the course of carrying on its business, as described in paragraphs 8, 9 and 10. ...