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You have confirmed that to the best of the knowledge of the Offering Partnership, the Production Services Partnership, the Production Co. and XXXXXXXXXX, none of the issues contained herein: a) is in an earlier return of the General Partner, the Initial Limited Partner, PSGP, the Production Co. or a related person; b) is being considered by a tax services office or taxation centre in connection with previously filed return of the General Partner, the Initial Limited Partner, PSGP, the Production Co. or a related person; c) is under objection by the General Partner, the Initial Limited Partner, PSGP, the Production Co. or a related person; d) is before the courts or, if a judgment 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 Canada Customs and Revenue Agency. ... Any amount of unpaid principal which the Production Services Partnership owes to PSGP under the Interim Production Loan will be a limited-recourse amount, as defined in subsection 143.2(1) of the Act, of the Production Services Partnership with the result that: (i) the provisions of subsection 143.2(6) of the Act will apply to reduce the Production Services Partnership's expenditures (including the amounts of the NCLE) to the extent that the amount of the Interim Production Loan can reasonably be considered to relate to such expenditures incurred by the Production Services Partnership; (ii) at the time that all or a portion of the Interim Production Loan is repaid by the Production Services Partnership, 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 payment, provided such repayment is not part of a series of loans or other indebtedness and repayments; and (iii) the Interim Production Loan 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 Offering Partnership or the cost of the Units in the Offering Partnership acquired by the Investors. ... Any amount owing by the Offering Partnership to: (i) the Production Services Partnership in respect of the unpaid portion of the subscription price in respect of Class A Units of the Production Services Partnership; and (ii) XXXXXXXXXX as described in 28 above, will be a limited recourse amount, as defined in subsection 143.2(1) of the Act, of the Offering Partnership with the result that: (i) the provisions of subsection 143.2(6) of the Act will apply to reduce the Offering Partnership's expenditures to the extent that the amount of such outstanding amounts can reasonably be considered to relate to such expenditures incurred by the Offering Partnership; (ii) at the time that all or a portion of the outstanding amounts are repaid by the Offering Partnership, 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 payments, provided such repayment is not part of a series of loans or other indebtedness and repayments; and (iii) the amount owing to the Production Services Partnership in respect of the Class A Units and the amount owing to XXXXXXXXXX referred to in 28 above will not, in and of itself, result in the application of subsection 143.2(6) of the Act to reduce the cost of the Units in the Offering Partnership acquired by the Investors. ...

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 (the "CCRA"). ... If an interest in the Production Services Partnership constitutes a tax shelter investment, within the meaning of subsection 143.2(1) of the Act, then by virtue of the application of subsection 143.2(8) of the Act, any amount of unpaid principal which the Production Services Partnership owes to XXXXXXXXXX under the Interim Production Loan or the Short-term Loan will be a limited-recourse amount, as defined in subsection 143.2(1) of the Act, of the Production Services Partnership with the result that: (i) the provisions of subsection 143.2(6) of the Act will apply to reduce the Production Services Partnership's expenditures (including the amounts of the NCLE) to the extent that the amount of the Interim Production Loan or the Short-term Loan can reasonably be considered to relate to such expenditures incurred by the Production Services Partnership; (ii) at the time that all or a portion of the Interim Production Loan, or the Short-term Loan, is repaid by the Production Services Partnership, 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 payment, provided such repayment is not part of a series of loans or other indebtedness and repayments; and (iii) the Interim Production Loan and the Short-term Loan 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 Offering Partnership or the cost of the Units in the Offering Partnership acquired by the Investors. ... If an interest in the Offering Partnership constitutes a tax shelter investment, within the meaning of subsection 143.2(1) of the Act, then by virtue of the application of subsection 143.2(8) of the Act, any amount owing by the Offering Partnership to the Production Services Partnership in respect of the unpaid portion of the subscription price in respect of Class A Units of the Production Services Partnership will be a limited-recourse amount, as defined in subsection 143.2(1) of the Act, of the Offering Partnership with the result that: the provisions of subsection 143.2(6) of the Act will apply to reduce the Offering Partnership's expenditures to the extent that the amount of such outstanding amounts can reasonably be considered to relate to such expenditures incurred by the Offering Partnership; at the time that all or a portion of the outstanding amounts are repaid by the Offering Partnership, 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 payments, provided such repayment is not part of a series of loans or other indebtedness and repayments; and the amount owing to the Production Services Partnership in respect of the Class A Units will not, in and of itself, result in the application of subsection 143.2(6) of the Act to reduce the cost of the Units in the Offering Partnership 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 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, any tax accounts, such as the balance of any non-capital losses, investment tax credits, RDTOH or CDA of Amalco, will not be considered property for purposes of the proposed transactions described herein. 12. ... Nothing in this letter should be interpreted as confirming that, (a) for purposes of the Act, any adjustment made pursuant to any such 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 such price adjustment clause, in respect of a transaction subsequent to the time of such transaction will be an additional payment of the redemption or purchase price of any shares redeemed or repurchased; or (c) in the event that any adjustment is made pursuant to any such price adjustment clause, the proposed transactions referred to above will be considered to have been carried out as described herein, in particular, for the purposes of the ruling C above The operation of a price adjustment clause is not a proposed transaction and, consequently, advance rulings are not given by the Department in respect thereof. ...

You have advised that to the best of your knowledge and that of the taxpayers involved none of the issues involved in this ruling 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, (d) is before the courts or, if a judgement 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 Directorate. ... The principal amount owing to Amalco by Holdco under the Holdco Note, as described in 23 above, will be set off against a portion of the principal amount owing to Holdco by Amalco (formerly Aco) under the Aco Note, as described in 18 above, and the Holdco Note will be cancelled and considered to be paid in full. ... For greater certainty, the proposed transactions described above, in and by themselves, will not be considered to result in any disposition of property 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 Taxpayers involved, none of the Proposed Transactions (as defined below) or the issues involved in this Ruling request are the same as or substantially similar to transactions or issues that are: (i) in a previously filed tax return of any of the Taxpayers or a related person and: A. being considered by the CRA in connection with such return; B. under objection by any of the Taxpayers or a related person; or C. the subject of a current or completed court process involving any of the Taxpayers or a related person; or (ii) the subject of a Ruling request previously considered by the Income Tax Rulings Directorate. ... For greater certainty, the Proposed Transactions described herein, in and of themselves, will not be considered to result in any disposition or significant increase in interest described in subparagraphs 55(3)(a)(i) to (v). ...

We understand that, to the best of your knowledge and that of the Taxpayers, none of the Proposed Transactions and/or issues involved in this Ruling are the same as, or substantially similar to, transactions and/or issues that are: a) in a previously filed return of the Taxpayers or a related person and; i. being considered by the Canada Revenue Agency in connection with such return; ii. under objection by the Taxpayers or a related person; or iii. the subject of a current or completed court process involving the Taxpayers or a related person; or b) the subject of a ruling previously considered by the Income Tax Rulings Directorate. ... For greater certainty, the Proposed Transactions described herein, in and of themselves, will not be considered to result in any disposition or significant increase in interest described in subparagraphs 55(3)(a)(i) to (v). ...

(v) Any Spinco Special Shares that are redeemed by Spinco as aforesaid will for all purposes be considered to have been redeemed on, and will be cancelled concurrently with, the payment of the Spinco Special Share Redemption Amount by Spinco to or for the benefit of the holder thereof. ... (v) Any DC Special Shares that are redeemed by DC as aforesaid will for all purposes be considered to have been redeemed on, and will be cancelled concurrently with, the payment of the DC Special Share Redemption Amount by DC to or for the benefit of the holder thereof. ... For greater certainty, in determining the consolidated, net fair market value of each type of property of DC, the following principles will apply: (i) any tax-related accounts in any corporation (such as deferred income taxes, the balance of non-capital losses and the balance of net capital losses) will not be considered to be property of DC; (ii) the amount of any liability will be its principal amount; (iii) no amount will be considered to be a liability unless it represents a true legal liability which is capable of quantification; (iv) the portion of the long-term debt due within one year will be treated as a current liability; and (v) the liabilities of any corporation in the DC Group will include its respective partnership share of each liability of any partnership of which such entity is a partner. ...

(vi) Any DC Special Shares that are redeemed by DC as aforesaid will for all purposes be considered to have been redeemed on, and will be cancelled concurrently with, the payment of the DC Special Share Redemption Amount by DC to or for the benefit of the holder thereof. ... (j) The Plan of Arrangement provides that any benefit received by DC as a result of the issuance by Spinco of Spinco Stock Options and other employee plan rights will be considered to be non-share consideration paid by Spinco in consideration for the Distribution Property. 92. ... As a result of the Subject Transactions or the Proposed Transactions, in and by themselves, none of DC, Bankco or Spinco will be considered to be a trader or dealer in Canadian resource properties for the purposes of subsection 66(5). ...

(t) For purposes of applying 7(q) above, (i) a Participant who is on an approved leave of absence, paid or unpaid, shall be considered in Relevant Employment; and (ii) any sale or withdrawal of Participant Shares from a Participant's Personal Account shall be deemed to be a sale or withdrawal of the earliest Participant Shares deposited in such account (i.e., first-in first-out basis), however, a Participant may elect to withdraw Dividend Shares or previously awarded Matching Shares from the Participant's Personal Account prior to withdrawing Participant Shares. ... To the best of your knowledge, none of the issues involved in this Ruling are: (i) in an earlier tax 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, a Participant or any person related to the Corporation or a Participant. ...

We understand that to the best of your knowledge and that of the taxpayers on whose behalf this ruling was requested, none of the issues described herein: (i) is in an earlier return of the taxpayer referred to above 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 referred to above or a related person; (iii) is under objection by the taxpayer referred to above or a related person; (iv) is before the courts or, if a judgement has been issued, the time limit for the appeal to a higher court has expired; and (v) is the subject of a ruling previously considered by the Income Tax Rulings Directorate. ...