Davies advised GMAC LLC with respect to its US$28.815 billion Outstanding Notes Exchange and Purchase Offers, and its separate Offers to Exchange and Purchase US$9.331 billion Outstanding Notes of Residential Capital, LLC, in respect of the Canadian tax considerations for holders taking up the offers.  Davies also prepared the Canadian tax sections for the Offering Memorandum for the first deal and for the Canadian Offering Memorandum for each of the two deals.  The Davies team included Nathan Boidman, Rhonda Rudick and Alan Shragie.

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