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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 taxpayer or a related person; (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 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 not expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... For the purposes of the Proposed Transactions, any tax accounts or other tax related amounts, such as loss carry-forwards, capital dividend account and refundable dividend tax on hand, will not be considered as property of DC. ...

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. ... In addition, (a) for the purpose of calculating the FMV of each type of property, as described above, DC will not have significant influence over any corporation; and (b) any tax accounts of DC, such as the amount of RDTOH account, the balance of any CDA, or any deferred income tax debit balance will not be considered property for purposes of the classification described herein. 24. ...

To the best of your knowledge and the knowledge of the taxpayers involved in the Proposed Transactions, none of the issues described in this ruling is: (a) in an earlier tax return of a taxpayer involved or a related person; (b) being considered by a tax services office or taxation centre in connection with any tax return previously filed by a taxpayer involved or a related person; (c) under objection or appeal by a taxpayer involved or a related person; (d) before the courts; or (e) the subject of a ruling previously issued to a taxpayer involved or a related person. ... 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 and the Corporation's knowledge, none of the issues involved in this ruling are: (i) in an earlier return of the Corporation, a Participant, or any person related to the Corporation or a Participant; (ii) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Corporation, a Participant, or any person related to the Corporation or a Participant; (iii) under objection by the Corporation, a Participant, or any person related to the Corporation or a Participant; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; nor (v) the subject of a ruling previously issued by the Directorate to the Corporation. ... Paragraph 7(3)(a) of the Act will apply where, as described in 13 above, an Executive enters into an XXXXXXXXXX with the Corporation in exchange for a release of any entitlement under the XXXXXXXXXX Plans such that, except as provided in section 7 of the Act as provided in C below, the Executive shall be considered to have neither received nor enjoyed any benefit as a result of entering into the XXXXXXXXXX or from acquiring Shares under the XXXXXXXXXX, to which subsection 5(1) or paragraphs 6(1)(a) or (i) of the Act would otherwise apply. ...

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 the purposes of the proposed transactions, any tax accounts or other tax related amounts, such as loss carry-forwards, capital dividend account and refundable dividend tax on hand, will not be considered as property of DC. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues involved in this ruling (i) is in an earlier return of the taxpayer(s) 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(s) or a related person, (iii) is under objection by the taxpayer(s) 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 Revenue Canada or the Canada Customs and Revenue Agency. ... Any amount of unpaid principal which the PLP owes on account of the Production Loans (the "Unpaid Loans") will be a limited-recourse amount of the PLP, with the result that: (i) the provisions of subsection 143.2(6) of the Act will apply to reduce the PLP's expenditures (including the amount of the Total NCLE) to the extent that the amount of the Unpaid Loans can reasonably be considered to relate to such expenditures incurred by the PLP; (ii) at the time that all or a portion of the Unpaid Loans are repaid by the PLP, the provisions of subsection 143.2(10) of the Act will apply to deem such expenditures to have been made or incurred at the time of, and to the extent of, the repayment; and (iii) the Unpaid Loans will not, in and of itself, result in the application of subsection 143.2(6) of the Act to reduce the cost of the Class A Units acquired by the MLP or the cost of the MLP Units acquired by the Investors. ...

We understand that to the best of your knowledge and that of XXXXXXXXXX/Aco, XXXXXXXXXX/Bco, and XXXXXXXXXX /Cco none of the issues contained herein: (a) is in an earlier return of XXXXXXXXXX/Aco, XXXXXXXXXX/Bco, XXXXXXXXXX/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 XXXXXXXXXX/Aco, XXXXXXXXXX/Bco, XXXXXXXXXX/Cco or a related person; (c) is under objection by XXXXXXXXXX/Aco, XXXXXXXXXX/Bco, XXXXXXXXXX/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: (a) any tax accounts, such as the balance of any RDTOH or capital dividend account of XXXXXXXXXX/Aco or any corporation over which XXXXXXXXXX/Aco has significant influence will not be considered property for purposes of the Butterfly Transfer; and (b) the portfolio investments and the advances from affiliated companies will be classified as investment property for the purposes of the Butterfly Transfer. 15. ...

Throughout this letter the corporate and individual taxpayers will be referred to as follows: XXXXXXXXXX Aco XXXXXXXXXX Daughter 1 XXXXXXXXXX Daughter 2 XXXXXXXXXX Father 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 the Canada Customs and Revenue Agency 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 Aco, will not be considered property for purposes of the proposed transactions described herein. 22. ...

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) 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) under objection by one 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 judgement has been issued, the time limit for appeal to a higher court has not expired. ... Comments Nothing in this letter should be considered as confirmation of the income tax consequences of any of the transactions described in this letter other than as specifically described. ...

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: (a) is 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 previously filed tax return of the taxpayer or a related person; (c) is under objection by the taxpayer 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 Directorate. ... For greater certainty, the proposed transactions described in paragraphs 6 to 15 above, in and by themselves, will not be considered to result in any of the events described in subparagraph 55(3)(a)(i) to (v). ...