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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 requested ruling is: (i) dealt with in an earlier return of LP, Finco or a related person; (ii) being considered by any tax services office or taxation centre in connection with a tax return already filed; (iii) under objection by LP, Finco or by a related person; (iv) the subject of a previously issued ruling by the Income Tax Rulings Directorate of the CRA to LP, Finco or a related party; nor (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired. ...

We understand that none of the issues involved in the ruling request is: (a) dealt with in an earlier return of the General Partner, Producer or that of a related person; (b) being considered by a Tax Services Office or a Tax Centre in connection with a previously filed tax return of the General Partner, Producer or that of a related person; (c) the subject of any notice of objection by the General Partner, Producer or a related person; (d) before the courts or is or has otherwise been under appeal by the General Partner, Producer or a related person; or (e) the subject of a ruling previously issued by the CRA to the General Partner, Producer or a related person. ...

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(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 judgement has been issued, the time limit for appeal to a higher court has expired; and (v) is the subject of a ruling previously issued by the Income Tax Rulings Directorate (other than in the previously issued ruling and supplementary ruling number XXXXXXXXXX and XXXXXXXXXX, respectively). ...

We also took into consideration the additional information provided in your letter dated XXXXXXXXXX, and the email correspondence we have exchanged between XXXXXXXXXX PRELIMINARY MATTERS: To the best of your knowledge, none of the issues involved in this Ruling Request: (a) is in an earlier return of Opco, or a related person; (b) is being considered by a tax services office or a taxation centre in connection with a previously filed tax return of Opco or a related person; (c) is under objection by Opco 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 expired; and (e) is 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 involved in this ruling request is: (a) dealt with in an earlier return of any of the taxpayers or a related person, (b) 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, (c) under objection by any of the taxpayers or a related person, (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired, or (e) the subject of a ruling previously issued to any of the parties or a related person by the Income Tax Rulings Directorate of the Canada Revenue Agency Our understanding of the facts, proposed transactions, other representations and the purpose of the proposed transactions are as follows: DEFINITIONS In this letter, unless otherwise expressly stated, the following terms have the meanings specified hereunder: (a) "ABL Credit Facility" means a senior secured credit facility denominated in XXXXXXXXXX between Opco, as borrower, and certain First Lien Lenders, as lenders. ...

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(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 judgement has been issued, the time limit for appeal to a higher court has expired; and (v) is the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

To the best of your knowledge, and that of the Taxpayers, none of the issues involved in this advance income tax ruling are: (i) in an earlier tax return of the Taxpayers or of a related person; (ii) being considered by a Tax Services Office or a Taxation Centre in connection with a previously-filed tax return of the Taxpayers or of a related person; (iii) under objection by the Taxpayers or by 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, other than the Initial Ruling, previously issued to the Taxpayers or a related person by the Income Tax Rulings 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, or (iv) before the courts. ...

To the best of your knowledge and that of each of the taxpayers, none of the issues involved in this ruling request is: in an earlier return of any of the taxpayers or a related person; 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; under objection by any of the taxpayers or a related person; before the courts; or the subject of a ruling previously issued by the Income Tax Rulings Directorate other than the advance income tax ruling issued on XXXXXXXXXX, 2006 (our reference 2006-020398) (the "Original Ruling") and the advance income tax ruling issued on XXXXXXXXXX, 2007 (our reference 2007-0232261R3)(the "Second Ruling"). ...

To the best of your knowledge, and that of the above-noted taxpayers, none of the issues involved in this advance income tax ruling request are: (i) in an earlier return of any of the above-noted taxpayers or a related person; (ii) being considered by a Tax Services Office or a Taxation Centre in connection with a previously-filed tax return of any of the above-noted taxpayers or a related person; (iii) under objection by any of the above-noted 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 to any of the above-noted taxpayers by the Income Tax Rulings Directorate. ...