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You have advised that to the best of the knowledge of the taxpayers and yourselves: (i) none of the issues involved in this ruling is under objection or appeal or is being considered by any district taxation offices or taxation centres of the Agency in connection with a tax return already filed; and (ii) none of the issues involved in the rulings is the subject of any notice of objection or is under appeal. ... Provided that Opco elects in the manner described in subsection 1103(2d) of the Regulations, Opco will be considered to have transferred a particular property included in class 2, 3, 6, 24, 27, 29, 34 or 39 to the "present class", within the meaning of that expression in subsection 1103(2d), in relation to the particular property, before the disposition of such assets to Sub1, as described in Paragraph 28. ...

We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in this ruling request: (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 income 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 (v) is the subject of a ruling previously issued by the Income Tax Rulings Directorate to the taxpayer or a related person. ... For greater certainty, DC does not expect to have any business property at the time of the proposed transactions and any tax accounts such as the balance of any RDTOH or CDA of DC will not be considered property for purposes of the proposed transactions 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, any tax accounts, such as the balance of any non-capital losses, RDTOH or CDA of Holdco, will not be considered to be property for purposes of the proposed transactions described herein. 20. ...

We understand that, 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 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 (v) is the subject of a ruling previously issued by the Income Tax Rulings Directorate to the taxpayer or a related person. ... For greater certainty, any tax accounts, such as the balance of RDTOH, will not be considered property for purposes of the proposed transactions. 22. ...

Position: Unitholders are not considered to have disposed of their units; there is no resettlement of the existing trusts due to the proposed amendments; 104(7.1) does not apply; There is no benefit or advantage to unitholders as a result of the proposed transactions. ... We understand that, to the best of your knowledge, none of the issues involved in this ruling request are: (a) in an earlier return of the taxpayer or a related person; (b) being considered by a tax services office and/or a tax centre in connection with a tax return previously filed by the taxpayer or a related person; (c) under objection by the taxpayer or a related person; (d) before the courts; or (e) the subject of a ruling previously issued by this Directorate to the taxpayer or a related person with the exception of ruling #952451. ...

XXXXXXXXXX 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 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 themselves, 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. ...

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 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, and there is no judgement that has been issued in which 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 and Interpretations 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. 14. ...

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, and (d) is before the courts or, if a judgement has been issued, the time limit for appeal has not expired. ... 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). ...

Provided the XXXXXXXXXX Loans arose from one or more loans or "lending assets" within the meaning of subsection 248(1), made or acquired by XXXXXXXXXX in the course of its money-lending business, the XXXXXXXXXX Loans reacquired by XXXXXXXXXX or the Inter-Company Loan acquired by XXXXXXXXXX as described in paragraph 30 above, will be considered to have been acquired by XXXXXXXXXX in the ordinary course of its money lending business for purposes of paragraphs 20(1)(l) and 20(1)(p). ... To the extent that XXXXXXXXXX assumes the liabilities of the Partnership immediately before the acquisition of XXXXXXXXXX interest in the Partnership (as described in paragraph 19 above) XXXXXXXXXX will be considered to have made a contribution of capital to the Partnership immediately before the Partnership ceases to exist. ...

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 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 greater certainty, any tax accounts of Opco, such as the balance of any losses available for carryforward, if any, will not be considered property of Opco for purposes of the proposed transactions described herein. 58. ...