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The paid-up capital of the amalgamated corporation, determined immediately after the amalgamation, will be considered the amount determined under s. 18(4)(a)(ii)(C) in respect of the calendar month in which the amalgamation occurs. 2. ... You have advised us that, to the best of your knowledge and that of the taxpayer involved, none of the issues involved in this ruling request are: (i) in an earlier return of the taxpayer or persons related to the taxpayer; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or persons related to the taxpayer; (iii) under objection by the taxpayer or persons related to the taxpayer; (iv) before the courts; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in this ruling request is: (i) in a 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 of the CRA. ... The status of XXXXXXXXXX [USCo5] and XXXXXXXXXX ULC [Canco1] as disregarded entities described in Paragraph 12 was necessary so that certain Completed Transactions would be considered disregarded transactions from a US tax perspective (e.g. the liquidation of XXXXXXXXXX [USCo5] into XXXXXXXXXX ULC [Canco1] as described in Paragraph 29). 51. ...

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 return of any 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 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, 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 Directorate to any of the Taxpayers or a related person (other than the Original Ruling). ... For greater certainty when considering the application of section 112, neither New LP, nor any of the LP Partners, will acquire, or be considered to have acquired the Preferred Shares in the ordinary course of business carried on by the respective entity. 22. ...

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 XXXXXXXXXX, any of its 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 XXXXXXXXXX, any of the its 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. ... For greater certainty when considering the application of section 112, neither New LP, nor any of the LP Partners, will acquire, or be considered to have acquired the Preferred Shares in the ordinary course of business carried on by the respective entity. 21. ...

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 person related to the taxpayers; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or a person related to the taxpayers; (iii) under objection by the taxpayers or a person related to the taxpayers; (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. ... For greater certainty, the Proposed Transactions, 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). ...

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 (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... For greater certainty, the Subject Transactions and the transactions described in Paragraphs 9, 17 and 18, in and by themselves, are not considered to result in any disposition or increase in interest described in subparagraphs 55(3)(a)(i) to (v). ...

You have advised us that to the best of your knowledge and that of the taxpayer 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 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) other than as noted above, 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 RDTOH or CDA of DC, will not be considered to be property of DC for purposes of the classification described in this Paragraph. 28. ...

You have advised that to the best of your knowledge, and that of the responsible officers of each of the taxpayers, none of the issues involved in this Ruling is: (i) in an earlier return of any of the taxpayers 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 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 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. ... DEFINITIONS In this letter, all monetary amounts are expressed in Canadian dollars unless otherwise indicated, and the following terms or expressions have the meaning specified: (a) "Act" means the Income Tax Act R.S.C. 1985 (5th Supp.) c.1 as amended from time to time and consolidated to the date of this letter and unless otherwise expressly stated every reference herein to a part, section or subsection, paragraph or subparagraph, and clause or subclause is a reference to the relevant provision of the Act, and the Income Tax Regulations thereunder are referred to as the Regulations; (b) "agreed amount" in respect of a property means the amount that the transferor and transferee of the property have agreed upon in an election under subsection 85(1); (c) "AL" means XXXXXXXXXX; (d) "AR" means XXXXXXXXXX; (e) "arm's length" has the meaning assigned by section 251; (f) "BA" means XXXXXXXXXX; (g) "BCA" means the Business Corporations Act (XXXXXXXXXX); (h) "BL" means XXXXXXXXXX; (i) "BN" means the business number issued to the particular entity by CRA; (j) "Canadian-controlled private corporation" has the meaning assigned by subsection 125(7); (k) "CRA" means the Canada Revenue Agency; (l) "DC" means XXXXXXXXXX; (m) "DE" means XXXXXXXXXX; (n) "dividend rental arrangement" has the meaning assigned by subsection 248(1); (o) "DP" means XXXXXXXXXX; (p) "eligible property" has the meaning assigned by subsection 85(1.1); (q) "EN" means XXXXXXXXXX; (r) "fair market value" means the highest price available in an open and unrestricted market between informed and prudent parties dealing at arm's length; (s) "F" means XXXXXXXXXX; (t) "financial intermediary corporation" has the meaning assigned by subsection 191(1); (u) "guarantee agreement" has the meaning assigned by subsection 112(2.2); (v) "J" means XXXXXXXXXX; (w) "LA" means XXXXXXXXXX; (x) "MU" means XXXXXXXXXX; (y) "OL" means XXXXXXXXXX; (z) "paid-up capital" has the meaning assigned by subsection 89(1); (aa) "Paragraph" refers to a numbered paragraph in this advance income tax ruling; (bb) "proceeds of disposition" has the meaning assigned by section 54; (cc) "Proposed Transactions" means the transactions described in Paragraphs 26 to 56; (dd) "related person" has the meaning assigned by section 251; (ee) "restricted financial institution" has the meaning assigned by subsection 248(1); (ff) "S" means XXXXXXXXXX; (gg) "safe-income determination time" has the meaning assigned by subsection 55(1); (hh) "safe income on hand" in respect of a particular share of a corporation at a particular time means the portion of the unrealized gain inherent in such share of the corporation 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; (ii) "series of transactions or events" includes the transactions or events referred to in subsection 248(10); (jj) "Sibling 1" means XXXXXXXXXX; (kk) "Sibling 1 Co" means XXXXXXXXXX; (ll) "Sibling 2" means XXXXXXXXXX; (mm) "Sibling 2 Co" means XXXXXXXXXX; (nn) "Sibling 3" means XXXXXXXXXX; (oo) "Sibling 3 Co" means XXXXXXXXXX; (pp) "specified financial institution" has the meaning assigned by subsection 248(1); (qq) "stated capital" has the meaning assigned by section XXXXXXXXXX of the BCA; (rr) "taxable dividend" has the meaning assigned by subsection 89(1); (ss) "taxable Canadian corporation" has the meaning assigned by subsection 89(1); (tt) "TCN" means XXXXXXXXXX; (uu) "TCO" means XXXXXXXXXX; (vv) "TG" means XXXXXXXXXX; (ww) "TG II" means XXXXXXXXXX; (xx) "TH" means XXXXXXXXXX; (yy) "TPH" XXXXXXXXXX; and (zz) "TPU" XXXXXXXXXX. ...

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 one of the taxpayers 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 one of the taxpayers or a related person; (iii) is under objection by one of the taxpayers 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 expired; or (v) is the subject of a ruling previously issued by this Directorate. ... For greater certainty, any tax accounts of DC1, including the balance of its RDTOH, its CDA, its GRIP account and any losses available for carry forward, will not be considered property of DC1 for the purposes of the Proposed Transactions. 15. ...

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 any of the taxpayers 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 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, 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. ... For greater certainty, the Proposed Transactions described herein, in and by themselves, will not be considered to result in a disposition or increase in interest described in subparagraphs 55(3)(a)(i) to (v) with respect to the dividends deemed to be received by Investco or any of the Holdcos described in Ruling C. ...