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We understand that, to the best of your knowledge and that of both Corporation A and Corporation B, none of the issues involved in this ruling request is: (a) in an earlier return of Corporation A or Corporation B or a related person; (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of Corporation A or Corporation B or a related person; (c) under objection by Corporation A or Corporation B or a related person; (d) before the courts; nor (e) the subject of a ruling previously issued to Corporation A or Corporation B or a related person by the Income Tax Rulings Directorate. ... The principal factors to be considered in making such determination are the professional responsibilities, career development and the alignment of compensation with growth of the corporate group as a whole, as measured by increase in shareholder value. 47. ...

To the best of your knowledge, and that of Holdco, none of the issues involved in this ruling as they apply specifically to Holdco and its subsidiaries herein: (i) is in an earlier return of Holdco 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 Holdco or a related person; (iii) is under objection by Holdco 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 expired; or (v) is the subject of a previously issued ruling. ... These triggering events will not be considered events of default but the failure of Holdco or Opco, as applicable, to make the offers as required or to comply with the terms of the offer once made will be listed as an event of default under the relevant credit documentation. ...

We understand that to the best of your knowledge and that of the taxpayer involved, none of the issues contained herein: (i) is in an earlier tax 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 by the taxpayer or a related person; (iv) is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired; or (v) is the subject of an advance income tax ruling previously issued by the Income Tax Rulings Directorate. ... A mine established for Zone A, in accordance with the mine plan described in paragraphs 18 to 19 above, will be considered to be a new mine in a mineral resource in Canada and subject to Comment ii) below, any expense incurred by X Co., after the date of this letter, for the purpose of bringing the mine into production in reasonable commercial quantities and incurred before the coming into production of the mine will be a Canadian exploration expense within the meaning of paragraph (g) of the definition thereof contained in subsection 66.1(6) of the Act, provided the expense does not constitute the cost, or any part of the cost, to X Co. of any depreciable property or Canadian resource property. ...

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 one or any of the taxpayers or a related person; (iii) under objection by one or any of the taxpayers or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings Directorate; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ... For the purposes of subsections 111(4), (5), (5.1), (5.2), and 249(4), SubCo will be considered to have acquired control of OpCo as a result of the share purchase by OpCo described in 28 above. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in the ruling are: (i) 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, or (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ... Loan will not be considered "indebtedness" within the meaning of the term in the indentures relating to the C Ltd. ...

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: i) contained in earlier returns of the taxpayers or a related person; ii) being considered by a tax service office and/or a tax centre in connection with a tax return previously filed by the taxpayers or a related person; iii) under objection by the taxpayers 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. ... Such a resolution will require approval of XXXXXXXXXX% of the votes cast at the meeting of Unitholders at which the resolution is considered. ...

V We understand that to the best of your knowledge and that of Aco, Bco and Cco none of the issues contained herein: (a) is in an earlier return of Aco, Bco or Cco 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 Aco, Bco or Cco or a related person; (c) is under objection by Aco, Bco or Cco or a related person; (d) is before the courts; or (e) is the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... For greater certainty, any tax accounts, such as the balance of RDTOH, pre-1972 CSOH, or capital dividend account of Aco, will not be considered property for purposes of the Proposed Transactions. 17. ...

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 one or any of the taxpayers or a related person; (iii) under objection by one or any of the taxpayers or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings Directorate; (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (vi) with respect to the exercise of the Call Option described in paragraphs 32 to 34 below or the payment of the subscription price by instalments, as described in paragraphs 13 and 14 below, dealt with in any documents or any agreements (either verbal or written), other than the documents and agreements that have been submitted to the Income Tax Rulings Directorate in draft form. ... For the purposes of paragraph 18.1(15)(a) of the Act, no portion of the Royalty will reasonably be considered to have been paid to another taxpayer, or to a person with whom the other taxpayer does not deal at arm's length, to acquire the right to receive production in respect of the Royalty from the other taxpayer. ...

A (collectively "the taxpayers"), none of the issues involved in the ruling request: (i) is in an earlier return of the taxpayers or a related person, (ii) is being considered by a tax services office or taxation center in connection with a previously filed tax return of the taxpayers or a related person, (iii) is under objection by the taxpayers 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 Income Tax Rulings Directorate. ... For greater certainty, any tax accounts, such as the balance of any losses available for carryforward, RDTOH, or capital dividend account of DCo, will not be considered property for purposes of the Proposed Transactions. 19. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein: (i) is in an earlier return of one of the taxpayers 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 one of the taxpayers or a related person; (iii) is under objection by one of the taxpayers or a related person; (iv) is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired; or (v) is the subject of a ruling previously issued by the Directorate. ... 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). ...