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We understand that to the best of your knowledge, and that of the taxpayers involved, none of the matters considered in this ruling request are: (a) in an earlier return of the taxpayers or related persons; (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the taxpayers or related persons; (c) under objection by the taxpayers or related persons; (d) before the courts; or (e) the subject of a ruling previously issued by this Directorate to the taxpayers or related persons. ...

To the best of your knowledge and that of the Corporation, and the Employees none of the issues involved in this ruling are: (a) in an earlier return of the Corporation or the Employees, or any person related to the Corporation or the Employees; (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Corporation or the Employees, or any person related to the Corporation or the Employees; (c) under objection by the Corporation or the Employees, or any person related to the Corporation or the Employees; (d) before the courts; nor (e) the subject of an income tax ruling previously issued by CCRA to the Corporation or the Employees. ... Paragraph 7(3)(a) of the Act will apply in respect of an Employee where, as described in 8 above, the Employee is granted rights under the Option Plan such that, except as provided in section 7 of the Act, as ruled on in C below, the Employee shall not be considered to have received or enjoyed any benefit to which subsection 5(1), paragraphs 6(1)(a) or (i) or section 15 of the Act would otherwise apply, as a result of the grants or from the acquisition of Shares under the Option Plan. ...

To the best of your knowledge and that of the taxpayers, none of the issues in this ruling request is: (i) 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; (ii) under objection by the taxpayer or a related person; or (iii) before the courts. ... For greater certainty, the proposed transactions described herein, in and by themselves, will not be considered to result in any disposition or increase in interest described in any of subparagraphs 55(3)(a)(i) to (v). ...

Additional Information To the best of your knowledge and that of the taxpayers involved, none of the issues involved with this ruling letter: (i) is under objection; (ii) is before the courts or, if a judgment has been issued, the time limit for appeal has not expired; or (iii) is being considered by a tax services office or a taxation centre in connection with a tax return already filed by one of the taxpayers or a related person. ... For these purposes, the amounts that are paid or payable under each of the OPCO 5 PTA, OPCO 2 PTA, OPCO 4 PTA and OPCO 3 PTA respectively will be considered to be deductible for that year in computing the amounts prescribed to be the exempt earnings from an active business of OPCO 5, OPCO 2, OPCO 4 and OPCO 3 respectively other than an active business carried on in Canada, to the extent that, before taking into account any such payment, OPCO 5, OPCO 2, OPCO 4 and OPCO 3 respectively have an amount of "exempt earnings" for that year from an active business, other than an active business carried on in Canada, as defined in subsection (1) of Regulation 5907, which equals or exceeds the amount of any such payment. ...

We understand that, to the best of your knowledge and that of the Taxpayers, none of the issues involved in the ruling request is: (i) 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 Taxpayer or a related person, (iv) before the courts, or (v) the subject of a ruling previously issued by the Directorate to the Taxpayers or a related person. ... Under no circumstances shall DSUs be considered to be Shares nor shall they entitle a Participant to exercise voting rights or any other rights attaching to the ownership of Shares; "Employer" means one of the two wholly owned incorporated subsidiaries of the Company that participate in the Plan, namely Subco and Canada Inc.; "Market Value" on a particular day means the average of the high and low prices per share at which Shares are traded on the XXXXXXXXXX (the "Exchange") on the last trading day before the particular day; "Net Redemption Amount" means the amount payable to a Participant after Applicable Canadian Withholding Taxes (with respect to an Officer Participant) or Applicable XXXXXXXXXX Withholding Taxes (with respect to a Canadian Director Participant) are deducted from the Redemption Amount; "Participant" means a Canadian resident individual for purposes of the Act who has elected to receive DSUs under the Plan and who is either (i) an officer of an Employer and on the payroll of an Employer ("Officer Participant") or (ii) a Canadian Director of the Company (together referred to as "Executives"); "Plan" means the DSU plan to be established by the Company for the Executives, the terms of which are described below; "Redemption Amount" means a Participant's entitlement under the Plan on the Participant's Redemption Date which amount shall be calculated by multiplying the number of DSUs in the Participant's Account by the Market Value of a Share on the Redemption Date; "Redemption Date" means such date as the Company may, in its sole discretion, decide, which date shall in no event be earlier than the date of the Participant's Termination and no later than the end of the first calendar year commencing after the Participant's Termination; "Shares" means XXXXXXXXXX shares in the capital of the Company and "Share" means one XXXXXXXXXX share in the capital of the Company; and "Termination" with respect to a Participant means the date upon which a Participant ceases to hold any position as a director or officer of the Company, an Employer or any subsidiary or affiliated company and is no longer otherwise employed by the Company, an Employer or any subsidiary or affiliated company, and includes the date of the death of a Participant. ...

We understand that, to the best of your knowledge, none of the issues involved in the ruling request: (i) is in an earlier return of the taxpayer or a related person, (ii) 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, (iii) is under objection or appeal by the taxpayer 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, and (v) is the subject of a ruling previously issued by the Directorate. ... Provided that a Partner providing Professional Services to Newco through a Contracting Company would not, but for the existence of the Contracting Company, be an officer or employee of Newco in respect of those Professional Services, then each such Contracting Company will not be considered to be carrying on a "personal services business" as defined by subsection 125(7) of the Act. ...

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 greater certainty, any tax accounts will not be considered property for purposes of the proposed transactions described herein. 23. ...

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 not expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... For greater certainty, any tax accounts of DC, such as deferred tax balances, will not be considered property for the purposes of the proposed transactions. 11. ...

We understand that, to the best of your knowledge, none of the issues involved in the ruling request: (i) is in an earlier return of the taxpayer or a related person, (ii) 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, (iii) is under objection or appeal by the taxpayer 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, and (v) is the subject of a ruling previously issued by the Canada Revenue Agency. ... Provided that a Partner providing Professional Services to Newco through a Contracting Company would not, but for the existence of the Contracting Company, be an officer or employee of Newco in respect of those Professional Services, then each such 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 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 taxation centre in connection with a previously filed tax return of 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 expired, and (v) the subject of a ruling previously issued to the taxpayer or a related person by this Directorate. ... C) The Plan will not be considered a "salary deferral arrangement" as that term is defined in subsection 248(1) by reason of the exception under paragraph (k) of that definition. ...