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A Director or Executive shall not be entitled to any certificate or other document evidencing the DSUs, and under no circumstances shall DSUs be considered Common Shares of XXXXXXXXXX, nor shall they entitle any Director or Executive to exercise voting rights or any other rights attaching to the ownership or control of Common Shares. h) The rights or interests of a Director or an Executive under the Plans shall not be assignable or transferable, otherwise than by testamentary disposition or in accordance with the laws governing the devolution of property in the event of death. i) After the Resignation Date, the Director or Executive shall be entitled, on the Settlement Date, to an amount equal to the number of DSUs standing to the credit, on that date, of the Director or Executive, as the case may be, multiplied by the Market Value of a Common Share of XXXXXXXXXX determined on the Settlement Date. ... To the best of your knowledge and belief, none of the issues or matters in respect of which rulings are being requested are being considered by a Tax Services Office or a Taxation Centre in connection with an income tax return already filed, and none of the issues is under objection or appeal. ...

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 of Investco, such as the balance of any losses available for carryforward and its RDTOH, will not be considered property of Investco for purposes of the proposed distribution described herein. 25. ...

To the best of your knowledge, and that of the taxpayers named herein, none of the issues involved in this advance income tax ruling request is under objection or appeal or is being considered by any tax services office or taxation centre of Revenue Canada in connection with any income tax return already filed. ... A shareholder of XXXXXXXXXX, as the case may be, who dissents from the Amalgamation will cease to be a shareholder of that corporation on the effective date of the Amalgamation and the shares of such a shareholder on which the right to dissent was exercised will no longer be considered to be outstanding as shares of that corporation for corporate law purposes. ...

You have advised that, to the best of your knowledge and that of responsible management of the taxpayers, none of the issues involved in this ruling application is being considered by a Taxation Services Office or a Taxation Centre of Revenue Canada in connection with any tax return already filed and that none of such issues is under objection or appeal. ... Provided that the Mortgage Loan arose from one or more loans made or acquired by XXXXXXXXXX in the course of its XXXXXXXXXX business, the Mortgage Loan reacquired by XXXXXXXXXX, as described in paragraph 17 of the Proposed Transactions, will be considered to have been acquired by XXXXXXXXXX in the ordinary course of its business of XXXXXXXXXX for the purposes of paragraphs 20(1)(l) and 20(1)(p) of the Act. ...

You have advised that, to the best of your knowledge and that of responsible management of the taxpayers, none of the issues involved in this ruling application is being considered by a Taxation Services Office or a Taxation Centre of Revenue Canada in connection with any tax return already filed and that none of such issues is under objection or appeal. ... Provided that the Mortgage Loan arose from one or more loans made or acquired by XXXXXXXXXX in the course of its insurance business, the Mortgage Loan reacquired by XXXXXXXXXX, as described in paragraph 17 of the Proposed Transactions, will be considered to have been acquired by XXXXXXXXXX in the ordinary course of its business of insurance for the purposes of paragraphs 20(1)(l) and 20(1)(p) of the Act. ...

We understand that to the best of your knowledge and that of the taxpayers involved, 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 or appeal. ... For greater certainty, any tax accounts, such as the balance of any RDTOH account or CDA of Distributor, will not be considered property of Distributor for purposes of the proposed transactions described herein. 25. ...

To the best of your knowledge and that of the taxpayers: a) None of the issues involved in this ruling request is being considered by any Tax Services Office and/or Taxation Centre in connection with any tax return already filed; and b) None of the issues involved in this ruling request is under objection or appeal. ... “Safe income on hand” refers to the income earned or realized, within the meaning of paragraph 55(5)(c) of the Act, by a corporation to the extent that it is on hand and can reasonably be considered to contribute to the capital gain that could be realized on a disposition at FMV of all of the common shares of the corporation. 19. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is being considered by a tax services office or a taxation centre in connection with any tax return already filed and none of the issues is under objection or appeal. ... For greater certainty, any tax accounts, such as the balance of any refundable dividend tax on hand or capital dividend account of XXXXXXXXXX, will not be considered to be property of XXXXXXXXXX for purposes of the proposed transactions described herein. ...

We understand that to the best of your knowledge and that of the taxpayers involved: (i) none of the issues involved in the requested rulings is being considered by a District Taxation Office or a Taxation Centre in connection with a tax return already filed, and (ii) none of the issues involved in the requested rulings is the subject of any notice of objection or is under appeal. ... The shares held by each shareholder have a fair market value ("FMV") in excess of the shareholder's ACB. 12) The Class XXXXXXXXXX shares held by each shareholder were acquired from XXXXXXXXXX in exchange for Class XXXXXXXXXX common shares of XXXXXXXXXX. 13) XXXXXXXXXX has incorporated a corporation, XXXXXXXXXX is authorized to issue an unlimited number of shares of the following classes: Class XXXXXXXXXX:- voting, participating, pre-emptive right to acquire any Class "XXXXXXXXXX" share offered for issue, (common) Class XXXXXXXXXX:- non-voting, participating, pre-emptive right to acquire any Class "XXXXXXXXXX" share offered for issue, (common) Class XXXXXXXXXX:- non-voting, non-participating, cumulative dividend at a rate of XXXXXXXXXX% per annum of the redemption amount, redeemable by corporation at issue price plus any unpaid dividends thereon (whether declared or not), non convertible, pre-emptive right to acquire any Class "XXXXXXXXXX" share offered for issue, priority over all other Classes of shares on liquidation or dissolution Class XXXXXXXXXX:- non-voting, non-participating, non-cumulative dividend rate at XXXXXXXXXX% per annum of redemption price, redeemable at option of holder at issue price plus any unpaid but declared preferential dividend thereon, no preemptive right, preferred over Classes "XXXXXXXXXX" shares, but no such dividend shall be paid until all the preferential cumulative dividends on the Class "XXXXXXXXXX" shares have been declared and paid, created for the special purpose of being issued in exchange for property (other than a promissory note or promise to pay) or issued shares of the Corporation of a different class or series, and may not be issued for any other purpose Class XXXXXXXXXX:- non-voting, non-participating, non-cumulative dividends at XXXXXXXXXX% per annum of issue price, redeemable by holder at issue price plus any unpaid but declared preferential dividend thereon, no pre-emptive right, preferred over Classes "XXXXXXXXXX" shares, but no such dividend shall be paid until all the preferential cumulative dividends on the Class "XXXXXXXXXX" shares have been declared and paid, created for the special purpose of being issued in exchange for property (other than a promissory note or promise to pay) or issued shares of the Corporation of a different class or series, and may not be issued for any other purpose Class XXXXXXXXXX:- voting, non-participating, redeemable and retractable at issue price, no pre-emptive right, dividends as declared by the Board, liquidation preference over Classes "XXXXXXXXXX" shares 14) XXXXXXXXXX does not own shares in any corporation over which it could be considered to have a significant influence or an interest in any partnership. 15) Immediately before the transfers described in paragraph 23 below, the property of XXXXXXXXXX will be classified into three types of property for the purposes of paragraph 55(3)(b) of the Act, as follows: (i) cash or near cash property, comprising all of the current assets of XXXXXXXXXX, including any cash, deposits, marketable securities and accounts receivable, inventory and rights arising from prepaid expenses and current portion of loan receivable from a related company; (ii) investment property, comprising all of the assets of XXXXXXXXXX other than cash or near cash property, any income from which would, for the purposes of the Act, be income from property or a specified investment business, within the meaning of subsection 125(7) of the Act. ...

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. ...