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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 tax return of the taxpayers or of any related persons; (ii) being considered by a tax services office or a tax centre in connection with a tax return already filed by the taxpayers or by any related persons; (iii) under objection by the taxpayers or any related persons; (iv) before the courts; or (v) the subject of a ruling previously issued by the Directorate to the taxpayers or to any related persons. ... Comments/Caveats Nothing in this letter should be construed as implying that the CRA has reviewed, confirmed or otherwise considered, in the context of issuing this letter: i. ...

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) is in an earlier return of any of the Taxpayers or a related person; (ii) is being considered by a tax services office or a taxation centre in connection with any previously filed tax return of any of the Taxpayers or a related person; (iii) is under objection by any of the Taxpayers or a related person; is before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has expired; or (iv) the subject of a ruling previously issued by the Directorate to any of the Taxpayers or a related person. ... For greater certainty, the Proposed Transactions, in and by themselves, will not be considered to result in any disposition of property to, or increase in interest by, an unrelated person 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 described 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) 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. ... To the extent that a portion of the Cdn Beneficiary's capital interest to be distributed can reasonably be considered to relate to a deemed taxable dividend received by the Trust (whether an eligible dividend or non eligible dividend), the trustees will pass a resolution for all or a portion of the balance to be distributed as an eligible dividend to the extent of eligible dividends received by the Trust in Paragraph 38 and as a non-eligible dividend for any remainder. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues involved with this request: (i) is involved in an earlier return of the taxpayer or a Related Person; (ii) is being considered by a tax services office or a taxation centre in connection with a tax return already filed by the taxpayer or a Related Person; (iii) is under objection by the taxpayer or a Related Person; or (iv) is before the courts or, if a judgment has been issued, the time limit for appeal has not expired. ... Nothing in this letter should be construed as implying that the CRA has considered, examined, agreed to or ruled on whether transfer pricing practices of entities in this letter are in accordance with section 247, or whether subsection 247(2) applies to the transactions described in this Ruling letter, except to the extent addressed by ruling L. ...

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 tax return of the taxpayers or a related person; (ii) being considered by a tax services office or a tax centre in connection with a tax return already 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. ... For greater certainty, the CRA has not considered, confirmed or made a determination in respect of: (a) whether Subco is, at any particular time, a XXXXXXXXXX as defined in subsection 248(1); (b) whether Trust I is, at any particular time, XXXXXXXXXX within the XXXXXXXXXX as defined in subsection 248(1); (c) whether the transfer of properties described in paragraphs 15, 17, 22 and 24, will meet the requirements under subsection 97(2); (d) whether the proposed amalgamation of Subco and Parent, as described in paragraph 39, will meet the requirements under section 87; (e) whether the principal amount and the FMV of the debt on the proposed distribution of the Subco Loan and the Subco Note by Trust I will equal the principal amount and the FMV of the debt outstanding at that time by Subco; (f) whether New XXXXXXXXXX will, at any time, be a XXXXXXXXXX; and (g) any income tax considerations associated with the additional information, as described in paragraphs 43 to 45 above. ...

We understand that to the best of your knowledge and that of the taxpayer involved, none of the issues described herein is: (i) dealt with 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, or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate (other than Ruling no. 2009-032021). ... The Guarantee Rights will not be considered as property acquired in substitution for Distributed Property at common law or as a result of the application of subsection 248(5). 45. ...

We understand that, to the best of your knowledge, and that of the taxpayers involved, none of the issues described herein is: (i) in an earlier return of the Partnership, any of the Partners or a related person; (ii) being considered by a Tax Services Office or Taxation Centre in connection with a previously filed return of the Partnership, any of the Partners or a related person; (iii) the subject of any notice of objection; (iv) before the courts or, if a judgment has been issued, the time limit for appeal has not expired; or (v) the subject of a previously issued ruling. ... The supply of Professional Services by the Particular Contracting Company to the Partnership as described in the proposed transactions will not be considered the carrying on of a personal services business. ...

To the best of your knowledge and that of the above-referenced taxpayer, none of the issues involved in this ruling is: (i) in an earlier return of the above-referenced 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 above-referenced taxpayer or a related person; (iii) under objection by the above-referenced taxpayer or a related person; (iv) before the courts; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... For the sake of this definition, direct or indirect ownership is determined based on actual ownership or deemed ownership under the presumptions included in the definition of "specified shareholder" in subsection 248(1); "Paragraph" refers to a numbered paragraph in this advance income tax rulings request; "Parent" means XXXXXXXXXX, a corporation incorporated under the Second Act wholly owned by Aco and continued as a XXXXXXXXXX limited liability company and thereafter amalgamated with Subsidiary#1 prior to the Effective Date; "Plan of Arrangement" means the plan of arrangement substantially in the form of Exhibit C of the Arrangement Agreement and any amendment thereto; "Public Corporation" has the meaning assigned by subsection 89(1); "Purchase Price" means $XXXXXXXXXX per Target Share; "Related" has the meaning assigned by section 251; "Replacement Options" means the options to acquire shares of Bidco (or an Affiliate of Bidco) granted in exchange for Target Options pursuant to the Arrangement Agreement; "Right of Payment" means the right to receive a cash payment issued by Bidco to Management as consideration for each Target Option and Rollover Target RSU as described in Paragraph 33 below; "Rollover Consideration" means collectively the Replacement Options for the Rollover Target Options, an equity interest in Shareholder 1 for the Rollover Target Shares and the Right of Payment totaling approximately $XXXXXXXXXX; "Rollover Target Options" means the Target Options held by Management exchanged for Replacement Options pursuant to the Arrangement Agreement; "Rollover Target RSUs" means the Target RSUs transferred on a taxable basis to Bidco in exchange for the Right of Payment in an amount equal to the Purchase Price, which right is contributed to Shareholder 1 for an equity interest in Shareholder 1; "Rollover Target Shares" means the portion of the Target Shares transferred, on a taxable basis, by Management to Shareholder 7 in exchange for an equity interest in Shareholder 1; "Safe Income on Hand of Target" in respect of particular shares 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 determined pursuant to subsection 55(5)), to the extent that it is on hand, by any corporation after 1971 and before the safe-income determination time for the transaction, event or series of transactions or events that includes the Proposed Transactions; "Second Act" means the XXXXXXXXXX; "Second Amalco" means the corporate entity resulting from the Second Amalgamation. ...

You confirm that to the best of your knowledge, none of the issues involved in the ruling request is: (a) in an earlier return of any of Subco, Parentco, A Co or X Entity (collectively, the "Applicants") or a related person; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of any of the Applicants or a related person; (c) under objection by any of the Applicants or a related person; (d) the subject of a ruling previously considered by the Income Tax Rulings Directorate, with the exception of a related prior ruling regarding the tax-exempt status of XXXXXXXXXX ("B Group") and XXXXXXXXXX ("C Group"), and which is relevant to Ruling A, below; nor (e) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

We understand that, to the best of your knowledge, and that of the taxpayers involved, none of the issues described herein is: (i) in an earlier return of the Partnership, any of the Partners or a related person; (ii) being considered by a Tax Services Office or Taxation Centre in connection with a previously filed return of the Partnership, any of the Partners or a related person; (iii) the subject of any notice of objection; (iv) before the courts or, if a judgment has been issued, the time limit for appeal has not expired; or (v) the subject of a previously issued ruling. ... Provided that the Principal of the Named Partner that provides Professional Services to the Partnership through the Particular Contracting Company would not, but for the existence of the Particular Contracting Company, reasonably be regarded as an officer or employee of the Partnership in respect of those services, then the Particular Contracting Company will not be considered to be carrying on a personal services business. ...