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We understand that 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 one of the taxpayers or a related person; (ii) under objection by the above-noted taxpayer or others identified herein or a related person; (iii) being considered by a Tax Services Office or Taxation Centre in connection with a tax return already filed of any one of the taxpayers or a related person; (iv) the subject of 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. ... COMMENTS Nothing in this ruling should be construed as implying that the CCRA has reviewed or is making a determination in respect of: (a) the fair market value or adjusted cost base of any particular asset or the paid-up capital of any share or class of shares referred to herein; (b) any tax consequences relating to the facts and proposed transactions described herein other than those specifically described in the rulings given above; (c) any tax consequences relating to a subsequent disposition of any shares or property by any person referred to herein, and nothing in this ruling should be construed as implying that any subsequent transaction will not be considered to be part of the series of transactions or events described herein. ...

To the best of your knowledge, and that of any of the taxpayers, none of the issues involved in this ruling request is: (i) involved 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; (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 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). ...

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 at Zone XXXXXXXXXX, in accordance with the mine plan described in paragraph 14 above utilizing the Zone XXXXXXXXXX Shaft, will be considered to be a new mine in a mineral resource in Canada and 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. ...

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;? ... the subject of a ruling previously considered by the Directorate. Definitions In this letter, the following terms have the meaning specified: Unless otherwise indicated, all references to statute are to the Income Tax Act, (Canada), R.S.C. 1985, c.1 (5th Supp.), as amended, (the "Act"); (a) "adjusted cost base", "capital property" and "proceeds of disposition" have the meanings assigned by section 54; (a.1) "agreed amount" in respect of a property means the amount that the transferor and transferee of the property have agreed upon in an election under subsection 85(1); (b) "Canadian-controlled private corporation", "income of the corporation for the year from an active business" and "specified investment business" have the meanings assigned by subsection 125(7); (c) "cost amount", "dividend rental agreement", "net income stabilization account ("NISA")" and "specified financial institution" have the meanings assigned by subsection 248(1); (c.1) "depreciable property" has the meaning assigned by subsection 13(21); (d) "dividend refund" has the meaning assigned by subsection 129(1); (e) "eligible property" has the meaning assigned by subsection 85(1.1); (e.1) "FMV" means fair market value; (f) "paid-up capital", "taxable Canadian corporation" and "taxable dividend" have the meanings assigned by subsection 89(1); (f.1) "prepaid expenses" means the rights arising from the prepayment of expenses; (g) "refundable dividend tax on hand" has the meaning assigned by subsection 129(3); (h) "related person" has the meaning assigned by subsection 251(2); (i) XXXXXXXXXX; and (j) "specified financial institution" has the meaning assigned by subsection 248(1); Our understanding of the facts, purposes of the proposed transactions and proposed transactions is as follows: Facts 1. ...

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. ...

You have confirmed that to the best of your knowledge and that of XXXXXXXXXX none of the issues contained herein: (a) is in an earlier return of XXXXXXXXXX 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 XXXXXXXXXX or a related person; (c) is under objection by XXXXXXXXXX or a 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 issued by the Income Tax Rulings and Interpretations Directorate of Revenue Canada. Definitions In this letter unless otherwise expressly stated: (a) "Act" means the Income Tax Act, R.S.C. 1985 (5th Supp.) c.1, as amended to the date hereof, and unless otherwise stated, every reference herein to a part, section, subsection, paragraph or subparagraph is a reference to the relevant provision of the Act; (b) "ACB" means "adjusted cost base" and has the meaning assigned by section 54; (c) "capital property" has the meaning assigned by section 54; (d) "Capitalized Amount" means an amount equal to the aggregate of: (i) the retained earnings of XXXXXXXXXX; (ii) the increase in the retained earnings of XXXXXXXXXX from XXXXXXXXXX to the time immediately before the time control of XXXXXXXXXX is acquired; and (iii) the contributed surplus of XXXXXXXXXX at the time immediately before the time control of XXXXXXXXXX is acquired; (e) "CBCA" means the Canada Business Corporations Act R.S.C. 1985 C-44 as amended to the date hereof; (f) "XXXXXXXXXX" means XXXXXXXXXX as described in Paragraph 3; (g) "XXXXXXXXXX" means XXXXXXXXXX, as described in Paragraph 2; (h) "XXXXXXXXXX" means XXXXXXXXXX as described in Paragraph 1; (i) "XXXXXXXXXX Shares" means all of the currently issued and outstanding shares of XXXXXXXXXX, being XXXXXXXXXX common shares; (j) "XXXXXXXXXX" means XXXXXXXXXX as described in Paragraph 2; (k) "Closing Date" means the date on which a favourable XXXXXXXXXX order is granted; (l) "Closing Time" means the time of the day on the Closing Date that the transfer of the XXXXXXXXXX Shares to XXXXXXXXXX becomes effective, which time is after a favourable XXXXXXXXXX order is granted; (m) "Conditions Precedent" means all of the conditions precedent which must be satisfied to complete the purchase and sale of the XXXXXXXXXX Shares pursuant to the Conditional Share Purchase Agreement as described in Paragraph 12; (n) "Conditional Share Purchase Agreement" means the conditional share purchase agreement as described in Paragraph 12 to be entered into between XXXXXXXXXX, as vendor of the XXXXXXXXXX Shares, XXXXXXXXXX, as purchaser of the XXXXXXXXXX Shares and XXXXXXXXXX as the owner of the XXXXXXXXXX Shares at the time the Conditional Share Purchase Agreement will be executed; (o) "Escrow Agreement" means the escrow agreement as described in Paragraph 13; (p) XXXXXXXXXX; (q) XXXXXXXXXX; (r) "XXXXXXXXXX" means XXXXXXXXXX, as described in Paragraph 7; (s) "paid-up capital" has the meaning assigned by subsection 89(1); (t) "Paragraph" refers to a numbered Paragraph in this letter; (u) "proceeds of disposition" has the meaning assigned by section 54; (v) XXXXXXXXXX; (w) XXXXXXXXXX; (x) "public corporation" has the meaning assigned by subsection 89(1); (y) "safe income on hand" in respect of shares of a corporation at a particular time means the portion of the unrealized gain inherent in the shares at that time that cannot reasonably be considered to be attributable to anything other than income earned or realized (as defined in paragraphs 55(5)(b), (c) or (d)), by the corporation after 1971 and before the safe-income determination time for the series of transactions that includes the dividend described in ruling A below; (z) "safe-income determination time" has the meaning assigned by subsection 55(1); (aa) "stated capital" has the meaning assigned by the XXXXXXXXXX; (bb) "Subco" means a subsidiary of XXXXXXXXXX to be incorporated as described in Paragraph 11; (cc) "Subco Shares" means the redeemable, retractable preference shares of Subco that will be issued to XXXXXXXXXX as consideration for the transfer of the XXXXXXXXXX Shares by XXXXXXXXXX to Subco, as described in Paragraph 15; (dd) "taxable Canadian corporation" has the meaning assigned by subsection 89(1); (ee) "XXXXXXXXXX" means XXXXXXXXXX, as described in Paragraph 6; (ff) "XXXXXXXXXX" means XXXXXXXXXX, as described in Paragraph 9; (gg) "XXXXXXXXXX" means XXXXXXXXXX, as described in Paragraph 4; (hh) "XXXXXXXXXX" means XXXXXXXXXX, as described in Paragraph 5; and (ii) "XXXXXXXXXX" means XXXXXXXXXX, as described in Paragraph 8. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues contained herein: (i) is in an earlier tax return 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 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; or (v) is the subject of an advance income tax ruling previously issued by the Income Tax Rulings and Interpretations Directorate of Revenue Canada. ... For greater certainty, the proposed transactions described in paragraphs 15 to 22 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) of the Act. ...

All DSUs recorded in a Participant's DSU Account shall vest immediately and shall not be considered forfeited upon the Participant's retirement or long-term disability as determined by the Committee, upon certain events (defined as a "Change in Control" in the Plan), upon the Participant's death or upon the termination of the Plan. 14. ... ADDITIONAL INFORMATION To the best of your knowledge and that of the Company, none of the issues involved in this ruling request are: a) in an earlier return of the Company or a related person, b) being considered by any tax services office or tax centre in connection with a previously filed tax return of the Company or a related person, c) the subject matter of any notice of objection filed pursuant to the Act by the Company or a related person, d) before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has not expired, and e) the subject of a ruling previously issued by this directorate. ...

To the best of your knowledge and that of XXXXXXXXXX and the other parties to this ruling request, none of the issues involved in this ruling request are: in an earlier return of the parties or related persons, being considered by a tax services office or taxation centre in connection with a previously filed tax return of the parties or related persons, under objection by one of the parties or a related person, before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has not expired, and the subject of a ruling previously issued by the Directorate, other than ruling 3-992401 dated XXXXXXXXXX, 1999. 25. ... F) Provided that, as of the date of this letter, the only statements and representations made or (as contemplated in subsection 237.1(1) of the Act at the definition of "tax shelter") proposed to be made in connection with interests acquired in XXXXXXXXXX after the date of this letter, are those in Exhibit XXXXXXXXXX, which was submitted as part of the advance income tax ruling request dated XXXXXXXXXX, none of XXXXXXXXXX will be considered to be a tax shelter within the meaning of subsection 237.1(1) of the Act. ...

We understand that, to the best of your knowledge and that of the Company, none of the issues involved in the ruling request (i) is in an earlier return of the Company or a related person, (ii) is being considered by a tax services office or tax centre in connection with a previously filed tax return of the Company or a related person, (iii) is under objection by the Company 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. ... Under no circumstances shall the Deferred Share Units be considered Common Shares of the Company nor shall they entitle any Eligible Director to exercise voting rights or any other rights attaching to the ownership of the Company's Common Shares. ...