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[Plan section XXXXXXXXXX] (f) In making a determination of an Incentive Amount, the Board shall consider the timing of crediting RUs to the Participant's Account and the vesting requirements applicable to such RUs to ensure that the crediting of the RUs to the Participant's Account and their vesting requirements are not considered a salary deferral arrangement for purposes of the Act and the XXXXXXXXXX [Plan section XXXXXXXXXX] For greater certainty, an Eligible Employee will not be credited with any RUs at the time the Incentive Amount is established but only when the Trustee credits RUs to the Participant's Account. ... To the best of your, the Group's and any Participants' knowledge, none of the issues involved in this ruling are: (i) in an earlier return of any member of the Group or a Participant, or any person related to any member of the Group or a Participant; (ii) being considered by a tax services office or tax centre in connection with a previously filed tax return of any member of the Group or a Participant, or any person related to any member of the Group or a Participant; (iii) under objection by any member of the Group or a Participant, or any person related to any member of the Group 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 any member of the Group or a Participant. ...

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 Holdings or any of the Newcos. ...

To the best of your knowledge, and that of the parties to this ruling, none of the issues contained in this advance income tax ruling: 1. is in an earlier return of the taxpayer or a related person; 2. is being considered by a tax services office or a taxation centre in connection with a previously filed tax return of the taxpayer or a related person; 3. is under objection by the taxpayer or a related person; 4. is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or 5. is the subject of a ruling previously issued by this Directorate. ... For greater certainty, the amount of any deferred income taxes will not be considered a liability for the purposes of the proposed transactions described herein because such amount does not represent a legal obligation of the particular corporation. 21. ...

To the best of your knowledge, and that of the parties to this ruling, none of the issues contained in this advance income tax ruling: 1. is in an earlier return of the taxpayer or a related person; 2. is being considered by a tax services office or a taxation centre in connection with a previously filed tax return of the taxpayer or a related person; 3. is under objection by the taxpayer or a related person; 4. is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or 5. is the subject of a ruling previously issued by this Directorate. ... In the event of a subsequent disposition of any shares of any of the companies referred to herein, nothing in this ruling should be construed as implying that the transactions described herein will not, for the purposes of subsection 55(3.1), be considered to be part of a series of transactions or events which includes such subsequent disposition of shares. 4. ...

You have been advised by your clients that to the best of their knowledge, none of the issues involved in this ruling request, as they apply specifically to such respective parties: (i) is in an earlier return; (ii) is being considered by a tax services office or taxation centre in connection with a previously filed tax return; (iii) is under objection; (iv) is before the courts; or (v) is the subject of a previously issued ruling. ... 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 to an unrelated person as described in subparagraphs 55(3)(a)(i) to (v). ...

You advise that to the best of the knowledge of the Offering Partnership, the Production Services Partnership and XXXXXXXXXX, none of the issues contained herein: (a) is in an earlier return of the Offering Partnership, the Production Services Partnership 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 Offering Partnership, the Production Services Partnership or a related person; (c) is under objection by the Offering Partnership, the Production Services Partnership 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 Income Tax Rulings and Interpretations Directorate of Revenue Canada. ... The cost of the Units to an Investor and the expenses of the Offering Partnership and the Production Services Partnership will be reduced by the amount of any limited recourse amount, as defined in subsection 143.2(1) of the Act, to the extent that such limited recourse amount can reasonably be considered to relate to such cost or expense. ...

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 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). ...

To the best of your knowledge and that of the Taxpayers, none of the issues involved in the ruling request is: i. in a previously filed tax 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 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. the subject of a current or completed court process involving the Taxpayers or a related person; or v. the subject of a ruling request previously considered by the Directorate. ...

CONFIRMATION To the best of your knowledge and that of the taxpayers involved, none of the proposed transactions or issues involved in this Ruling request are the same as or substantially similar to transactions or issues that are: i. in a previously filed return of the taxpayers or a related person and: A. being considered by the CRA in connection with such return; B. under objection by the taxpayers or a related person; or C. the subject of a current or completed court process involving the taxpayers or a related person; or ii. the subject of a Ruling request previously considered by the Income Tax Rulings Directorate. ...

PRELIMINARY MATTERS To the best of your knowledge, and that of the responsible officers of the above-noted taxpayer, none of the recently completed transactions or issues involved in this ruling request are the same as or substantially similar to transactions or issues that are: (a) in a previously filed tax return of the above-noted taxpayer or a related person and: i. being considered by the CRA in connection with such return; ii. under objection by the above-noted taxpayer or a related person; or iii. the subject of a current or completed court process involving the above-noted taxpayer or a related person; or (b) the subject of a ruling request previously considered by the Income Tax Rulings Directorate in relation to the taxpayer or a related person. ...