Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.
Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ADRC.
Principal Issues: 1. Is the operation of the parking lot or the making of loans to the development company undertakings that would disqualify the trust as a MFT under subsection 132(6)?
2. Are unsecured loans to a single purpose corporation and the development company property described in 108(2)(b)(iii)(D)?
3. Will the trust's liability (either the debt assumed or the joint and several, or solidary, liability for property held in undivided co-ownership) result in a prohibited undertaking for the purpose of 108(2) and 132(6)?
4. Will 75(2) apply to the sub-trust by reason of the genuine loan of cash by the beneficiary?
5. Will 75(2) apply to attribute income from the single purpose trust to the settlor, the sub-trust and will 107(2) apply whenever the single purpose trust distributes the property to the sub-trust?
6. Will the interest paid in the year or payable in respect of the year on the sub-trust Loan be deductible by sub-trust pursuant to the provisions of paragraph 20(1)(c) of the Act?
7. Will the single purpose trust and sub-trust be personal trusts within the meaning of subsection 248(1)?
8. Will the interest-bearing loan to the single purpose trust constitute foreign property?
9. Does 15(1) or 246(1) apply as a result of the employee service agreement for services to be provided in respect of property wholly-owned by the trust?
Position: 1. No. 2. Yes 3. No 4. No 5. 75(2) applies but 107(4.1) doesn't apply to the distribution of the property to the person from whom the property was received 6. Yes to the extent that the single purpose trust continues to use the funds for the purpose of earning income from property and the sub-trust continues to be the sole beneficiary of the single purpose trust and provided that the amount is not in excess of a reasonable amount 7. Yes 8. No 9. No.
Reasons: 1. Parking lot issue considered in previous ruling 2001-0075693.
2. What is common to the terms "bonds, debentures, mortgages, notes and other similar obligations" in 108(2)(b)(iii)(D) is indebtedness, a legal obligation and written evidence of that fact whereas the level of security of each term is variable.
3. It is not the liability but the actions that give rise to the liability that could constitute an undertaking other than those described in 108(2)(b)(ii) or 132(6).
4. Q.8 at 1991 CTF roundtable
5. Although 75(2) applies when the settlor is a capital beneficiary of the trust, 107(4.1) does not apply if the property, or property substituted for it, is distributed to that settlor.
6. The sub-trust is the sole beneficiary of the single purpose trust which will hold the income earning property and there is no power of appointment to add additional beneficiaries. As such the requisite linking has been established.
7. Neither are unit trusts and no one acquired an interest in either for consideration, taking 108(7) into consideration.
8. A debt is not an interest in a trust for the purpose of (i) of the def'n of foreign property in 206(1). However, the sub-trust's beneficial interest in the single purpose trust is foreign property.
9. As stated in paragraph 5 of IT-432R2, 15(1) does not apply where the transaction is a bona fide business transaction. Various external texts on secondments, particularly in the area of Transfer Pricing (e.g., BNA Transfer Pricing Reports vol 10#16, 10#20) suggest that no mark up is required on a true secondment arrangement. While secondments are generally of a temporary nature and do not normally involve split duties, there could be valid business reasons for a long-term, split-duty arrangement. In this case, it is clear that direction and control of the employee will rest with the trust as the secondee for duties related to the management of the properties wholly owned by the trust and that the employee services agreement was negotiated based on business factors and not on the fact that the trust is the sole shareholder of the management company. Based on jurisprudence such as ABC Steel Buildings Ltd. v. MNR (74 DTC 1124), Detchon (96 DTC 2032) and Youngman (90 DTC 6322), for the purpose of 15(1), the shareholder does not realize a benefit simply because the management corporation does not realize a profit on the secondment agreement.
XXXXXXXXXX 2002-016846
Attention: XXXXXXXXXX
XXXXXXXXXX, 2002
Dear XXXXXXXXXX:
Re: Advance Income Tax Ruling
XXXXXXXXXX
This is in reply to your letter of XXXXXXXXXX, as amended by your letter of XXXXXXXXXX, in which you requested an advance income tax ruling in respect of the income tax consequences arising from the proposed transactions described below. We acknowledge your subsequent submissions of XXXXXXXXXX, and our related correspondence and telephone conversations.
To the best of your knowledge and that of the taxpayers on whose behalf this ruling is requested, none of the issues involved in this 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 any one of the taxpayers or a related person,
(iv) before the courts and no judgment has been issued in respect thereof, or
(v) the subject of a ruling previously considered by the Directorate in respect of the taxpayers or a related person.
Definitions
In this letter, unless otherwise indicated, all statute references are to the Income Tax Act and Regulations, R.S.C. 1985 (5th supp.) c. 1, as amended (the "Act"), and the following terms have the meaning specified:
"Amalco" means the corporation that will result from the amalgamation of XXXXXXXXXX Following the amalgamation, XXXXXXXXXX% of the voting shares will be owned indirectly by XXXXXXXXXX and persons related to him and XXXXXXXXXX % of the voting shares will be owned indirectly by XXXXXXXXXX and persons related to him. XXXXXXXXXX is a non-resident of Canada within the meaning of the Act and XXXXXXXXXX is a resident of Canada within the meaning of the Act;
"Assets" means the movables, fixtures and leasehold improvements, other than the Management Assets, which are owned by the Group and relate to the Properties and for greater certainty includes the trade name "XXXXXXXXXX" and related trademarks;
"Convertible Debenture" means the convertible debenture in the approximate principal amount of $XXXXXXXXXX to be issued by the Trust as partial consideration for the acquisition of the Properties;
"Co-Owned Properties" means the XXXXXXXXXX;
"Development Co" means XXXXXXXXXX, a company incorporated under the Canada Business Corporations Act, all of the issued share capital of which will be owned directly or indirectly by XXXXXXXXXX and which company will acquire vacant land for development and commercial properties located in Canada;
"Group" means XXXXXXXXXX;
"Initial Trustees" of the Trust means XXXXXXXXXX. They are all resident in Canada and they all deal at arm's length with the Group;
"Management Assets" means the assets owned by the Group (other than those assets used or operated exclusively in respect of the management of properties that will be wholly-owned by the Trust), which are used and operated in respect of the management of the Properties;
"MCO" means XXXXXXXXXX formed under the Canada Business Corporations Act, all the issued and outstanding shares of which will be owned by the Trust;
"Offering" means the offer of the Units of the Trust to the public as described in paragraph 8 below;
"Properties" means collectively the XXXXXXXXXX owned or co-owned by the Group;
"Property 1" means the XXXXXXXXXX;
"Settlor" means XXXXXXXXXX, a corporation incorporated under the Canada Business Corporations Act which is directly or indirectly owned by the Underwriters;
"Single Purpose Trust" means XXXXXXXXXX, a trust to be settled by the Sub Trust for the sole benefit of the Sub Trust, the initial trustee of which will be XXXXXXXXXX, a resident of Canada;
"Sub Trust" means XXXXXXXXXX, a trust to be established by the Settlor, for the sole benefit of the Trust, the initial trustees of which will be XXXXXXXXXX, who are both residents of Canada;
"Sub Trust Loan" means the loan to be made by the Trust to the Sub Trust, the terms of which are substantially the same as the terms set out in the draft promissory note submitted for our review;
"Trust" means XXXXXXXXXX, a closed-end investment trust established on XXXXXXXXXX by the Settlor;
"Underwriters" means a syndicate of underwriters to be lead by XXXXXXXXXX; and
"Units" means units of the Trust as described in paragraph 3 below.
The Trust, the Single Purpose Trust, the Sub Trust, MCO, and Development Co deal with the XXXXXXXXXX Tax Services Office. The corporations will file their returns at the XXXXXXXXXX Tax Centre and the trusts will file their returns at the XXXXXXXXXX
Our understanding of the facts and proposed transactions and the purpose of the proposed transactions is as follows:
Facts
1. The Settlor settled the Trust by contributing $XXXXXXXXXX and the Trust issued to the Settlor one Unit. The Settlor will redeem the Unit immediately following the closing of the Offering for the amount of $XXXXXXXXXX.
2. The Trust was established by way of a contract of trust under the laws of the Province of XXXXXXXXXX and is a resident of Canada for purposes of the Act. The operations of the Trust will be subject to the control and authority of XXXXXXXXXX trustees. The Initial Trustees of the Trust consist of at least XXXXXXXXXX independent trustees who deal at arm's length with the Group. Until completion of the proposed transactions described herein, the trustees of the Trust will be the Initial Trustees. Upon the completion of the proposed transactions, the Group will have the right to appoint additional trustees depending on the percentage of outstanding Units owned by the Group at that time. At all times a majority of the trustees will be independent trustees and therefore the Group will not control the Trust at any time. If at any time a majority of the trustees are not independent trustees because of the death, resignation, bankruptcy, adjudicated incapacity, removal or change in circumstance of any trustee who was an independent trustee, then the requirement to have a majority of independent trustees shall not be applicable for a period of XXXXXXXXXX days thereafter, during which period the remaining independent trustees must appoint a sufficient number of independent trustees so as to constitute a majority.
3. The Trust is authorized to issue an unlimited number of Units of one class, each of which represents a unitholder's proportionate undivided beneficial interest in the Trust. The attributes of each unit, including the units to be issued as part of the proposed transactions, will be identical.
4. It is intended that the Trust will satisfy the conditions in paragraph 108(2)(b) of the Act such that it qualifies as a unit trust at all times. It is also intended that the Trust will comply with prescribed conditions relating to the number of unitholders, dispersal of ownership of its Units and public trading of its Units as set out in paragraph 132(6)(c) and that the Trust will make the election contemplated by subsection 132(6.1) that it be deemed to be a mutual fund trust from the time it was established.
5. All the Properties are located in Canada.
6. The terms of the mortgage, which secures a debt of approximately $XXXXXXXXXX held on Property 1, require that Property 1 be owned by a single purpose entity and prevent such entity from any further borrowing.
Proposed Transactions
7. Units will be offered to the public by the Trust pursuant to the terms of a prospectus to be filed with the securities regulatory authority in each province of Canada. The price per Unit under the Offering will be arrived at through arm's length negotiations between the Trust and the Underwriters. The amount of the gross proceeds of the Offering are expected to be approximately $XXXXXXXXXX. The Units of the Trust will be listed on the XXXXXXXXXX Stock Exchange at the closing of the Offering.
8. The Trust will use the proceeds of the Offering to pay issue expenses, discharge certain debts affecting the Properties and to fund a portion of the cash consideration payable as part of the following transactions that will be completed immediately upon the closing of the Offering:
a) Subsequent to the transaction described in paragraph 22 below, the Trust will acquire from the Group all the Properties in respect of which the Group has a 100% ownership interest (other than Property 1) as well as the Assets, for their fair market value. The consideration payable will consist of cash, the issuance of Units, a Convertible Debenture and the assumption of certain indebtedness.
b) The Trust will loan the necessary funds to the Sub Trust to enable the Sub Trust to acquire Property 1 as described in paragraphs 12 and 13 below.
c) The Trust will invest, by way of an interest-bearing loan and share capital subscription, the necessary funds in MCO in order for MCO to acquire the Management Assets.
9. Upon completion of the proposed transactions, the Group will be entitled to receive as consideration for the sale of the Properties approximately XXXXXXXXXX% of the total outstanding Units, depending on the size of the Offering, with the balance of the Units being held by the public. As a result of the proposed transactions, the Group will also be entitled to receive the Convertible Debenture having a principal amount of $XXXXXXXXXX which, if converted to Units immediately following the proposed transactions, would result in the Group receiving approximately XXXXXXXXXX additional Units, thereby increasing their interest by approximately XXXXXXXXXX%.
10. The Trust will enter into a Property Development Agreement, a draft copy of which was submitted for our review, with Development Co under which the Trust will have the option to provide Development Co with mezzanine financing on market terms to fund a portion of the costs incurred by Development Co to develop new properties in exchange for the right to acquire such newly developed properties at completion of the development. It is expected that the Trust will make mezzanine interest-bearing loans to Development Co or to a similarly constituted corporation which is covered by the Property Development Agreement.
11. The Settlor will establish the Sub Trust with a contribution of $XXXXXXXXXX. The Trust will not make any payment directly or indirectly to the Underwriters or to the Settlor to reimburse them for the $XXXXXXXXXX contribution. The property held in the Sub Trust will not revert to the Settlor nor will the Settlor have any control or influence over the affairs of the Sub Trust.
12. Upon the closing of the Offering, the Trust will lend the Sub Trust approximately $XXXXXXXXXX under the terms of the Sub Trust Loan. The interest-bearing Sub Trust Loan will be fully repayable by XXXXXXXXXX, which corresponds to the term of the first mortgage on Property 1.
13. The Sub Trust will contribute the borrowed funds to the Single Purpose Trust. The purpose of the contribution is to allow the Sub Trust to acquire an indirect interest in Property 1, such that the income generated from Property 1 will accrue for the sole benefit of the Sub Trust. The Single Purpose Trust will acquire Property 1 and will enter into an agreement with the Sub Trust under which the Sub Trust will have the right of first refusal in the event of the proposed sale of Property 1 prior to XXXXXXXXXX. The Single Purpose Trust will acquire Property 1 for a purchase price of approximately $XXXXXXXXXX. The consideration payable for the interest will be satisfied by the assumption of the mortgage in the approximate amount of $XXXXXXXXXX and the balance of $XXXXXXXXXX will be paid in cash or a combination of cash, Units or the transfer of a convertible debenture. The Single Purpose Trust will acquire from the Trust any Units or debenture required to satisfy the purchase price.
14. Following the closing of the Offering, the Trust will also seek to acquire the Group's interest in the Co-owned Properties (i.e., a XXXXXXXXXX% undivided interest in XXXXXXXXXX of the Co-Owned Properties and a XXXXXXXXXX% undivided interest in XXXXXXXXXX of the Co-Owned Properties). With respect to each co-owned property, each co-owner has a right of first refusal on the purchase of the other co-owner's interest within a specified time following an offer to purchase that other co-owner's interest in the co-owned property. The other co-owner deals at arm's length with the Trust and the Group. In the event the Trust is unable to acquire the Group's interest in one or more of the Co-owned Properties, it will seek to acquire other real property located in Canada.
15. The liability between the co-owners is joint and such liability between them is based on their respective undivided interest in the Co-Owned Properties. However, the liability of the co-owners towards third parties, such as mortgage creditors, property managers, contractors, is generally on a joint and several, or solidary, basis.
16. The member of the Group that is selling its undivided interest in XXXXXXXXXX of the Co-Owned Properties is indebted to one or more creditors for amounts which are secured by the respective Co-Owned Properties. No other co-owner of the particular Co-Owned Property is liable for such amount and the member of the Group which owns the Co-Owned Properties must indemnify the other co-owners for any loss they may suffer as a result of any failure to pay the indebtedness. The Trust, as partial consideration for the acquisition of these particular Co-Owned Properties, will assume 100% of such indebtedness, which amount does not exceed the fair market value of the undivided interest being acquired by the Trust. The Trust alone will be responsible to repay 100% of the aforesaid indebtedness to the said creditors, which indebtedness is secured by the property in its entirety, and the Trust must therefore indemnify the other co-owners for any loss they may suffer as a result of the Trust's failure to pay the indebtedness.
17. All employees of the Group who render services to the Trust solely in relation to properties wholly-owned by the Trust and operated exclusively for the benefit of the Trust will be employed by the Trust. All other employees of the Group who manage and administer the Properties will be employed by MCO. The employment contract obligations of MCO towards certain senior employees to be engaged by MCO will be guaranteed by the Trust. The Trust and MCO will enter into an employee service agreement, a copy of which was submitted for our review, under which MCO will second its employees to the Trust with the Trust having a first priority right to the services of such employees with respect to the property and asset management of properties wholly-owned by the Trust. While performing services for the Trust, the seconded employees will be subject to the direction, control and supervision of the Trust and the Trust alone will be responsible for any acts or omissions of such employees during such time. The Trust shall provide such direction through the trustees of the Trust collectively. As a result, the Trust will, by virtue of the employee service agreement, be in a position to directly manage all the properties wholly-owned by the Trust.
18. Pursuant to the employee service agreement, the Trust will reimburse MCO for its share of all costs and expenses, including salaries and overhead incurred by MCO related to the employees seconded to the Trust. The employee service agreement between the Trust and MCO will have an initial term of XXXXXXXXXX years. In addition, the Trust will lease the necessary space to MCO for it to carry out its operations and will support all the necessary costs associated with maintaining the infrastructure through its direct employment of the employees of the Group who render services to the Trust solely in relation to properties wholly-owned by the Trust and operated exclusively for the benefit of the Trust.
19. MCO will also provide a full range of services, including property and facilities management, leasing, design, development, redevelopment, construction management, and administrative and legal services to third parties with respect to properties in which the Trust does not have any interest, as well as with respect to properties in which the Trust only has a co-ownership interest. MCO will charge the owners of such property a fee to be negotiated. With respect to the Co-Owned Properties, MCO will charge fees to the Trust and the other co-owners of such property. In respect of such fees, the Trust and the other co-owners will be jointly and severally, or solidarily, liable to MCO and as between them, their liability is joint based on their respective undivided interest in the property.
20. Certain of the Properties have underground, multi-level and/or surface parking lots beneath or adjacent to the Properties, the main purpose of which is to serve the tenants of the buildings, including their clients or customers. Any additional properties that the Trust may acquire in the future may also have underground, multi-level or surface parking lots beneath or adjacent to them. A fee will be charged by the Trust for the use of the parking spaces either on a monthly, daily or half-hourly basis. Any parking lot operations undertaken by the Trust will be part of the leasing and managing of the Properties or any additional properties that the Trust may acquire.
21. One of the Properties in which the Trust will acquire a XXXXXXXXXX% interest is a XXXXXXXXXX.
22. XXXXXXXXXX.
23. The Properties to be acquired by the Trust are located in Canada and will constitute capital property to the Trust.
24. The Trust is not being established or maintained primarily for non-residents of Canada. The contract of trust will contain restrictions on the ability of non-residents to own Units of the Trust such that non-residents may not be the beneficial owners of more than XXXXXXXXXX% of the Units.
Purposes of the Proposed Transactions
25. The purpose of the proposed transactions is to establish an investment trust vehicle that will be able to raise funds in the capital markets for the purpose of acquiring the Properties and to make investments in other real property. The purpose of the Sub Trust and Single Purpose Trust is to permit the Trust to acquire and finance Property 1 which it cannot do directly due to the terms of the mortgage affecting that property.
Rulings Given
Provided that the preceding statements constitute a complete and accurate disclosure of all the relevant facts, proposed transactions and purposes of the proposed transactions, and provided that the proposed transactions are carried out as described above, our rulings are as follows:
A. The operation of the parking lots, as described at paragraph 20 above, will constitute an undertaking of managing real property or an interest in real property for the purposes of paragraph 132(6)(b) and subparagraph 108(2)(b)(ii).
B. A mezzanine loan from the Trust to Development Co or to a similarly constituted corporation in the business of property development as described in paragraph 10 above and the Sub Trust Loan described in paragraph 12 above will constitute an undertaking described in paragraph 132(6)(b) and subparagraph 108(2)(b)(ii).
C. A mezzanine loan from the Trust to Development Co or to a similarly constituted corporation in the business of property development as described in paragraph 10 above which has terms that are substantially similar to the terms set out in the draft promissory notes and Property Development Agreement submitted with this ruling request, and the Sub Trust Loan described in paragraph 12 above constitute property described in clause 108(2)(b)(iii)(D).
D. The joint and several, or solidary, liability of the Trust, as described in paragraph 15 above, with respect to the Co-Owned Properties will not, in and of itself, disqualify the Trust from meeting the requirements of paragraph 132(6)(b) or subparagraph 108(2)(b)(ii).
E. The assumption of liability described in paragraph 16, by the Trust as partial consideration for the acquisition of four of the Co-Owned Properties will not, in and of itself, disqualify the Trust from meeting the requirements of paragraph 132(6)(b) or subparagraph 108(2)(b)(ii).
F. Subsection 75(2) will not apply as a result of the initial contribution to the Sub Trust described in paragraph 11 above, the Sub Trust Loan as described in paragraph 12 above, or any property substituted therefor, in and by themselves.
G. Any income or loss from Property 1 held by the Single Purpose Trust as described in paragraphs 12 and 13 above or from property substituted therefor, and any taxable capital gain or allowable capital loss from the disposition of such property, shall be deemed to be income or a loss, as the case may be, or a taxable capital gain or allowable capital loss, as the case may be, of the Sub Trust pursuant to subsection 75(2).
H. Provided that the amount is not in excess of a reasonable amount, interest paid in the year or payable in respect of the year on the Sub Trust Loan pursuant to the loan agreement described in paragraph 12 above, will be deductible by the Sub Trust pursuant to the provisions of paragraph 20(1)(c).
I. The Sub Trust and Single Purpose Trust will each be a "personal trust" within the meaning subsection 248(1).
J. Provided that the Single Purpose Trust does not make an election under subsection 107(2.001), subsection 107(2) will apply in respect of the distribution of Property 1 or any property acquired in the substitution therefor to the Sub Trust by the Single Purpose Trust provided the Sub Trust is resident in Canada at the time of the distribution.
K. The Sub Trust Loan will not constitute foreign property within the meaning of subsection 206(1).
L. No amount will be included in the income of the Trust pursuant to subsection 15(1) or 246(1) solely as a result of the secondment of employees from MCO for the purpose of administering the properties wholly-owned by the Trust on a cost recovery basis.
M. The provisions of subsection 245(2) will not be applied as a result of the implementation of the proposed transactions, in and by themselves, to redetermine the tax consequences confirmed herein.
The above rulings are given subject to the general limitations and qualifications set out in Information Circular 70-6R5, and are binding on the Canada Customs and Revenue Agency (the CCRA) provided that the proposed transactions are completed on or before the date that is six months from the date of this letter. These rulings are based on the Act in its present form and do not take into account the effects of any proposed amendments thereto.
Nothing in this letter should be construed as implying that the CCRA has agreed to or accepted any tax consequences arising from the facts or proposed transactions described above other than those specifically confirmed in the rulings given. In particular, it is noted that in order for a trust to qualify as a unit trust for any period of time where the conditions in paragraph 108(2)(a) and (c) are not met, the trust must meet the conditions in 108(2)(b). As the conditions in paragraph 108(2)(b) are dependant on the nature of XXXXXXXXXX held by the trust and the income from such property at a particular point in time, no assurance can be given that a trust which meets the conditions in paragraph 108(2)(b) at a particular point in time will continue to do so.
For example, subparagraph 108(2)(b)(v) requires that not more than 10% of the trust's property consists of bonds, securities or shares in the capital stock of any one corporation or debtor other than Her Majesty in right of Canada or a province or a Canadian municipality. For this purpose, the term "securities" includes all forms of indebtedness to a particular corporation or debtor. Consequently, any investment by the Trust in the debt of Development Co will not, in and by itself, result in the Trust property consisting of more than 10% in the bonds, securities or shares of any one corporation or debtor for purposes of subparagraph 108(2)(b)(v) of the Act provided that the aggregate cost amount of the debt owed by Development Co to the Trust and any shares or other securities of Development Co held by the Trust does not represent more than 10% of the aggregate cost amount of all properties owned by the Trust.
With respect to ruling K, we note that although the Sub Trust Loan will not constitute foreign property, the Trust's beneficial interest in the Sub Trust will qualify as foreign property.
The above rulings should not be construed as providing the CCRA's views on whether the Trust will qualify as a mutual fund trust for purposes of the Act.
XXXXXXXXXX
for Director
International and Trusts Division
Income Tax Rulings Directorate
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