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Principal Issues: Will we rule favorably that the purchase by an NRO of previously existing non-arm's length debt (i.e. debt that was not incurred in contemplation of the proposed transactions) would not be considered the "making of a loan" for purposes of the definition of non-resident-owned investment corporation in subsection 133(8)? ... To the best of your knowledge and that of the taxpayers involved, none of the issues involved in this request: (a) is involved in an earlier return of the taxpayers or a related person, (b) is being considered by a tax services office or taxation centre in connection with a tax return already filed by the taxpayers or a related person, (c) is under objection, or (d) is before the courts or, if a judgement has been issued, the time limit for appeal has not expired. ...

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, the proposed transactions described in paragraphs 9 to 27, in and by themselves, will not be considered to result in any of the events described in subparagraphs 55(3)(a)(i) to (v). ...

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 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; 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 non-capital losses, RDTOH or CDA of Opco, will not be considered property for purposes of the proposed transactions described herein. ...

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. ... For greater certainty, any tax accounts, such as the balance of RDTOH, pre-1972 CSOH or capital dividend account of XXXXXXXXXX, will not be considered property for purposes of the proposed transactions described herein. 21. ...

A Participant shall not be entitled to any certificate or other document evidencing the RSUs, and under no circumstances shall RSUs be considered Shares, nor shall they entitle any Participant to exercise voting rights or any other rights attaching to the ownership or control of Shares; (h) the rights or interests of a Participant under the Plan 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, and such rights shall not be encumbered; (i) after the Resignation Date of a Participant, the Participant shall be entitled, on the Settlement Date, to an amount equal to the number of RSUs standing to the credit of the Participant, multiplied by the Market Value of the Shares determined on the Settlement Date; (j) all expenses of administration of the Plan will be borne by the Corporation; (k) in the event that the Shares are subdivided or consolidated into a different number of Shares, the number of RSUs recorded in the account of the Participant shall be adjusted by replacing such number by a number equal to the number of Shares which would have been held by the Participant immediately after the subdivision or consolidation, should the Participant have held a number of Shares equal to the number of RSUs recorded in the Participant's account, on the record date for such subdivision or consolidation; (l) in the event that the Shares are exchanged into or exchanged for a different number or kind of securities of the Corporation or of another corporation, there shall be substituted for each Share referred to in the Plan the kind of securities into which each Share has been changed or for which each Share has been exchanged, and an equitable adjustment shall be made, if required, in the number of RSUs recorded in the account of the Participant; (m) in the event that there are other changes in the number or kind of outstanding Shares or of any securities into which Shares have been changed or exchanged, there shall be substituted for each Share referred to in the Plan or for each security into which the Share has been changed or exchanged, the kind of securities into which each Share or each such security has been so changed or exchanged, and an equitable adjustment shall be made in the number of RSUs recorded in an executive's account; (n) in the event that, at the Settlement Date, there is no public market for Shares or for securities substituted therefor, the obligations of XXXXXXXXXX under the Plan shall be satisfied by a payment in cash in such amount as is reasonably determined by the Committee to be fair and equitable in the circumstances. ... To the best of your knowledge, none of the issues involved in this ruling: i) are in an earlier return of the Corporation or a person related to the Corporation; ii) are being considered by a tax services office or tax centre in connection with a previously-filed tax return of the Corporation or a person related to the Corporation; iii) are under objection by the Corporation or a person related to the Corporation; iv) are before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired, and v) are the subject of a ruling previously issued by the Directorate. 8. ...

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; (g) "Deferred Share Unit Amount" has the meaning given thereto in 7(f) below; (h) "Dividend Equivalents" means a bookkeeping entry whereby each Deferred Share Unit is credited with the equivalent amount of the dividend paid on a Common Share; (i) "Eligible Director" means a person who is, at the relevant time, a director or former director of the Company who is not an employee of the Company or any of its subsidiaries; (j) "Market Value" means the last sale price of a board lot of Common Shares on XXXXXXXXXX Stock Exchange on the last trading day on such exchange prior to the particular date on which there was a trade of a board lot of Common Shares; and (k) "Redemption Date" means the date upon which an Eligible Director ceases to be a member of the Board. 7. ... To the best of your knowledge and the knowledge of the Company, none of the issues involved in this request for an advance income tax ruling: (a) is in an earlier return of the Company or of a person related to the Company; (b) is being considered by a tax services office or tax centre in connection with a previously filed return of the Company or of a person related to the Company; (c) is under objection by the Company or by a person related to the Company; (d) is before the courts; or (e) is the subject of a ruling previously issued by the Income Tax Rulings and Interpretations Directorate. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein 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 taxpayers or a related person; (iv) before the courts or, if a judgement 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 Directorate. ... For greater certainty, the proposed transactions described in paragraphs 8 to 19 above, 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). ...

We understand that to the best of your knowledge and that of the taxpayers involved none of the issues involved in the requested rulings is being considered by a tax services office or a taxation centre in connection with a tax return already filed, or is under objection or appeal. ... For this purpose, Amalco will be considered to have significant influence over a corporation if it has the ability to exercise significant influence, within the guidelines provided by section 3050 of the CICA Handbook, over that corporation or over any corporation which has significant influence over that corporation. 13. ...

To the best of your knowledge and the knowledge of the responsible officers of the taxpayers involved, none of the issues involved in the requested rulings is being considered by a Tax Services Office or Taxation Centre in connection with an income tax return already filed and none of the issues involved is subject to a notice of objection or is otherwise under appeal. ... Comments Nothing in this letter should be interpreted as confirming that: (a) for purposes of the Act, any adjustment made pursuant to any price adjustment clause in respect of a transaction subsequent to the time of such transaction will be effective, retroactively, to the time of such transaction; (b) for the purposes of the Act, any amount paid pursuant to any price adjustment clause, in respect of such transaction subsequent to the time of such transaction will be an additional payment on the redemption of any shares redeemed; or (c) in the event that any adjustment is made pursuant to any price adjustment clause, the proposed transactions referred to above will be considered to have been carried out as described herein. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues involved in this request (a) is involved in an earlier return of the taxpayer or a related person, (b) is being considered by a tax services office or taxation centre in connection with a tax return already filed by the taxpayer or a related person, (c) is under objection (d) is before the courts or, if a judgment has been issued, the time limit for appeal has not expired, and (e) is the subject of a ruling previously issued by the Income Tax Rulings and Interpretations Directorate. ... For greater certainty, any tax accounts, such as the balance of any RDTOH account or CDA of Opco, will not be considered property of Opco for purposes of the proposed transactions described herein. 13. ...