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We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in the ruling request: (i) is in an earlier return of the taxpayers or a related person; (ii) is being considered by a Tax Services Office or Taxation Center in connection with a previously filed tax return of the taxpayers or a related person; (iii) is under objection by the taxpayers 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; or (v) is the subject of a ruling previously issued by the Directorate. ...

For the purpose of applying Article X of the Convention, the amount of a dividend referred to in Ruling A or B will be considered to be income as described in the definition "dividends" in Article X(3) of the Convention that is derived by US Holdco. ...

The address and business number of the various companies in the affiliated group described herein are as follows: Name Address Business Number Holdco XXXXXXXXXX XXXXXXXXXX Opco 1 XXXXXXXXXX XXXXXXXXXX Opco 2 XXXXXXXXXX XXXXXXXXXX Opco 3 XXXXXXXXXX XXXXXXXXXX Lossco 1 XXXXXXXXXX To be determined (New corporation) Lossco 2 XXXXXXXXXX To be determined (New corporation) Newco XXXXXXXXXX To be determined (New corporation) We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling request herein is: (i) dealt with in an earlier return of Holdco, Opco 1, Opco 2, Lossco 1, Lossco 2, Newco or a related person; (ii) being considered by a tax services office or a taxation centre in connection with a tax return already filed by Holdco, Opco 1, Opco 2, Lossco 1, Lossco 2, Newco or a related person; (iii) under objection by Holdco, Opco 1, Opco 2, Lossco 1, Lossco 2, Newco or a related person; (iv) the subject of a previous ruling issued by the Income Tax Rulings Directorate to the taxpayers or a related person; nor, (v) before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

Other Information Other than as outlined in 13 and 14 above, to the best of your knowledge and that of Canco, none of the issues involved in this advance income tax ruling is: in an earlier return of Canco or a related person; being considered or under assessment by a tax services office or taxation centre in connection with a previously filed tax return of Canco or a related person; under objection by Canco or a related person; before the courts, and no judgement has been issued which may be under appeal; or the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling request herein are: (i) dealt with in an earlier return of Profitco, Lossco or a related person; (ii) being considered by a tax services office or a taxation centre in connection with a tax return already filed by Profitco, Lossco or a related person; (iii) under objection by Profitco, Lossco or a related person; (iv) the subject of a previous ruling issued by the Income Tax Rulings Directorate to the taxpayers or a related person; nor (v) before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

You have advised that to the best of your knowledge, and that of the taxpayers involved, none of the issues contained involved in this advance income tax ruling is: in an earlier return of the taxpayers, or a related person; being considered or under assessment by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or a related person; under objection by the taxpayers or a related person; before the courts, and no judgement has been issued which may be under appeal; or the subject of a ruling previously issued by the Directorate. ...

We understand that, 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 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 (v) the subject of a ruling previously issued by the Directorate to the taxpayers or a related person. ...

We understand that, to the best of your knowledge and that of the taxpayer, none of the issues involved in the ruling request is: (i) in an earlier return of the taxpayer 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 taxpayer or a related person, (iii) under objection by the taxpayer or a related person, (iv) before the courts, or (v) the subject of a ruling previously issued by the Directorate to the taxpayer or a related person. ...

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 Taxpayers or a related person; (ii) being considered by a Tax Services Office or Taxation Centre in connection with a previously filed return of the Taxpayers 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 XXXXXXXXXX Our understanding of the facts, proposed transactions and the purpose of the proposed transactions is as follows: DEFINITIONS In this letter, unless otherwise expressly stated: (a) "A Co" means XXXXXXXXXX., a corporation XXXXXXXXXX (b) "Acquisition Agreement" means the agreement entered into on XXXXXXXXXX, between the Predecessor Partnership and the Partnership pursuant to which the Partnership purchased all or substantially all of the assets of the Predecessor Partnership, in consideration for (a) the assumption by the Partnership of all or substantially all of the Predecessor Partnership's liabilities, including deferred revenue, (b) the issuance to the Predecessor Partnership of Partnership Units, (c) the Acquisition Promissory Note and (d) the Working Capital Note. ...

To the best of your knowledge and that of the taxpayer, none of the issues involved in this request for an advance income tax ruling is: (i) dealt with in an earlier return of the taxpayer or a related person; (ii) being considered by any tax services office or taxation centre in connection with a tax return previously filed by the taxpayer or a related person; (iii) under objection by the taxpayer or by a related person; (iv) the subject of a previously issued ruling 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 expired. ...