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To the best of your knowledge and that of the Taxpayers, none of the issues involved in the ruling request is: i. in a previously filed tax return of the Taxpayers or a related person; ii. 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; iii. under objection by any of the Taxpayers or a related person; iv. the subject of a current or completed court process involving the Taxpayers or a related person; or v. the subject of a ruling request previously considered by the Directorate. ...

To the best of your knowledge and that of the Taxpayers, none of the issues involved in the ruling request is: i. in a previously filed tax return of any of the Taxpayers or a related person; ii. being considered by a tax services office or a tax 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. the subject of a current or completed court process involving the Taxpayers or a related person; or v. the subject of a ruling request previously considered by the Directorate. ...

To the best of your knowledge and that of the Taxpayers involved, none of the issues contained in this ruling request is: 1. in a previously filed return of the Taxpayers or a related person; 2. being considered by a tax services office or a taxation centre in connection with a previously filed tax return of the Taxpayers or a related person; 3. under objection by the Taxpayers or related person; 4. before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or 5. the subject of a ruling previously considered by the Income Tax Rulings Directorate. ...

To the best of your knowledge and that of the Taxpayers, none of the issues involved in the ruling request is: i. in a previously filed tax return of any of the Taxpayers or a related person; ii. being considered by a tax services office or a tax 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. the subject of a current or completed court process involving the Taxpayers or a related person; or v. the subject of a ruling request previously considered by the Directorate. ...

We understand that to the best of your knowledge and that of the Taxpayer’s, none of the issues described herein: (a) is in a previously filed tax return of the Taxpayer or a related person; (b) is 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; (c) is under objection by the Taxpayer or a related person; (d) is the subject of a current or completed court process involving the Taxpayer or a related person; or (e) is the subject of a ruling previously considered by the Income Tax Rulings Directorate. ...

To the best of your knowledge, and that of the parties to this ruling, none of the issues contained in this advance income tax ruling is being considered by a Tax Services Office and/or a Taxation Centre in connection with an income tax return previously filed and none of the issues contained herein is under objection or appeal. ... In the event of a subsequent disposition of any shares of XXXXXXXXXX, nothing in this ruling should be construed as implying that the transactions described herein will not, for the purposes of paragraph 110.6(7)(a), be considered as part of a series of transactions or events which includes such subsequent disposition of shares. ...

To the best of your knowledge and that of the taxpayers concerned, none of the issues involved in this advance ruling request is being considered by a Tax Services Office or a Taxation Centre in connection with a tax return already filed and none of the issues is under objection. ... For greater certainty, any tax accounts, such as the balance of any net capital loss carry-forwards will not be considered to be property of XXXXXXXXXX for purposes hereof. ...

You advise that to the best of your knowledge and that of XXXXXXXXXX, none of the issues involved in the ruling request has been considered by a taxation services office or a taxation centre in connection with a tax return already filed, and none of the issues involved in the ruling request is the subject of any notice of objection or is under appeal. ... RULINGS GIVEN Provided all relevant facts, proposed transactions and their purposes have been fully disclosed and, as summarized above, are accurate, we confirm the following: A.The shares to be issued to XXXXXXXXXX, as described in paragraph 22 above will be: (a)shares described in subparagraph (e)(iii) of the definition of "term preferred share" in subsection 248(1) of the Act for a period not exceeding five years from the date of their issuance and, (b)"exempt shares" pursuant to paragraph (c) of the definition thereof in subsection 112(2.6) for that same period and, accordingly, subsections 112(2.1), 112(2.2), 112(2.3) or 112(2.4) of the Act will not apply to deny XXXXXXXXXX a deduction under subsection 112(1) of the Act for dividends received or deemed to have been received by it on such shares during such period; B.No amount will be included in the income of Subco C pursuant to paragraphs 12(1)(c) or 12(1)(x) or subsections 12(3), 12(9), 16(1), or 246(1) or section 9 of the Act in respect of capital contributions made or required to be made by XXXXXXXXXX to Subco C, as described in paragraph 24 above, nor will such amounts constitute proceeds of disposition, as defined in section 54 of the Act, to Subco C from the disposition by it of any property; C.Section 80 of the Act will not apply to XXXXXXXXXX by virtue of the fact that interest will not be paid or payable by XXXXXXXXXX to Subco C in respect of the XXXXXXXXXX Debt referred to in paragraph 21 above or by virtue of the failure of Subco C to demand payment of the XXXXXXXXXX Debt; D.Subject to paragraph 20(1)(e.1) of the Act, expenses incurred by Subco C in the course of borrowing money and issuing shares will be deductible pursuant to paragraph 20(1)(e) of the Act to the extent such expenses are reasonable in the circumstances; E.The cost amount, within the meaning of subsection 248(1) of the Act, of the Subco C Shares to XXXXXXXXXX, as described in paragraph 22 above, immediately after their issuance will be equal to the amount paid by XXXXXXXXXX for those shares; F.The cost amount, within the meaning of subsection 248(1) of the Act, to Subco C of the XXXXXXXXXX Debt will, immediately after it is acquired from XXXXXXXXXX by Subco C, as described in paragraph 21 above, will equal the purchase price paid thereof; G.No amount will be included in computing the income of XXXXXXXXXX under subsection 56(2) of the Act in respect of any capital contributions made by XXXXXXXXXX to Subco C, as described in paragraph 24 above; H.If the XXXXXXXXXX Debt is reacquired by XXXXXXXXXX pursuant to agreements described in paragraph 31 above, the cost amount, within the meaning of subsection 248(1) of the Act, to XXXXXXXXXX, of the debt immediately after it is acquired will be the purchase price paid therefor; I.No amount will be included in the income of XXXXXXXXXX pursuant to subsections 15(1) or 246(1) of the Act solely by virtue of the fact that interest will not be paid or payable by XXXXXXXXXX to Subco A in respect of the XXXXXXXXXX Debt as described in paragraph 21 above or as a result of the provision of the guarantee by Subco C to XXXXXXXXXX also described in paragraph 21 above; J.Provided that the XXXXXXXXXX Debt arose from one or more loans made by XXXXXXXXXX in the course of its money lending business, the XXXXXXXXXX Debt reacquired by XXXXXXXXXX as described in paragraph 21 above will be considered to have been acquired by XXXXXXXXXX in the ordinary course of its business of lending money for the purposes of paragraphs 20(1)(l) and 20(1)(p) of the Act; K.Subsection 112(4) of the Act will not apply to any loss realized by XXXXXXXXXX on the XXXXXXXXXX Debt subsequent to the reacquisition of this debt by XXXXXXXXXX in respect of any dividends received by XXXXXXXXXX on the Subco C Shares; L.By virtue of paragraph 84(1)(c.3) of the Act, no dividend will be deemed to have been paid by Subco C when it increases its stated capital as described in paragraph 30 above; M.No amount will be included in the income of Subco C pursuant to subsections 12(3), 12(9), 20(14) or section 9 of the Act in respect of the interest accrual described in paragraph 24 above; N.An amount will be deductible by XXXXXXXXXX pursuant to paragraph 20(1)(c) of the Act in respect of the interest accrual described in paragraph 24 above only where the transfer described therein occurs in the taxation year in which the interest accrued. ...

Other than those identified in this letter, there will be no agreements between the parties to the proposed transactions described herein that could reasonably be considered to impact on the rulings given in this letter. To the best of your knowledge and that of the parties involved, none of the issues involved in this ruling are being considered by a Tax Services Office or a Taxation Centre in connection with a tax return already filed, and none of the issues are under appeal or objection. ...

Other than those identified in this letter, there will be no agreements between the parties to the proposed transactions described herein that could reasonably be considered to impact on the rulings given in this letter. To the best of your knowledge and that of the parties involved, none of the issues involved in this ruling are being considered by a Tax Services Office or a Taxation Centre in connection with a tax return already filed, and none of the issues are under appeal or objection. ...