This tax instruction letter is provided in connection with the Arrangement pursuant to which Whitecap Resources Inc. acquired all the common shares of TORC and continued to operate as Whitecap Resources Inc. This tax instruction letter is for use by the former holders of common shares of TORC ("TORC Shares") who wish to recognize a capital gain as a result of the Arrangement by making a tax election with Whitecap under subsection 85(1) of the Income Tax Act (Canada) (the "Tax Act") or, in the case of a TORC Shareholder that is a partnership, under subsection 85(2) of the Tax Act (in either case, a "Tax Election").