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.
Principal Issues: 1. Creation & granting of a royalty from partnership to partner- Does the royalty qualify as CRP? ; 2.restructuring asset holdings within the group of related entities in order to avoid 132(7)
Position: 1. Royalty qualifies as CRP. 2. proposed transactions would enable fund to take advantage of 132(7)(a) exception
Reasons: 1.It was determined that the partnership would have an interest in XXXXXXXXXX for purposes of proposed paragraph XXXXXXXXXX of the CRP definition & the terms of the Royalty would respect the 90% threshold for the Production Revenue Component; 2. Given that the royalty will be CRP held by the fund & it will no longer be neccessary for a fund to have held CRP since inception, the 132(7)(a) exclusion will be available.
XXXXXXXXXX 2006-017435
Attention: XXXXXXXXXX
XXXXXXXXXX, 2006
Dear XXXXXXXXXX:
Re: Advance Income Tax Ruling
XXXXXXXXXX --Account Number XXXXXXXXXX
(formerly XXXXXXXXXX)
This is in reply to your letters of XXXXXXXXXX in which you request an advance income tax ruling in respect of the above-noted taxpayer. We also acknowledge your correspondence of XXXXXXXXXX.
We understand that to the best of your knowledge, and that of the taxpayers involved, none of the matters considered in this ruling request are:
a) in an earlier return of the taxpayers or related persons;
b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the taxpayers or related persons;
c) under objection by the taxpayers or related persons;
d) before the courts; or
e) the subject of a ruling previously issued by this Directorate to the taxpayers or related persons except as explained below in paragraph 1.
The documentation submitted with your request does not form part of the facts and proposed transactions and any references thereto are provided solely for the convenience of the reader. Unless otherwise indicated, all references to monetary amounts are in Canadian dollars and all statute references are to the Income Tax Act (Canada) (R.S.C. 1985, 5th Supplement, c.1, as amended) (the "Act") or to the Income Tax Regulations (the "Regulations").
I. DEFINITIONS
In this letter, the following words and phrases are defined as follows.
"Amalco" means XXXXXXXXXX, a corporation subject to the CBCA. All of Amalco's common shares are owned by the Trust. The only material assets of Amalco at the time of the Reorganization will be accounts receivable owing from other members of the Trust group.
"Bank Debt" means the Trust's bank debt described in paragraph 6.
"CBCA" means the Canada Business Corporations Act.
"CCDE" means cumulative Canadian development expense as defined in subsection 66.2(5).
"CCEE" means cumulative Canadian exploration expense as defined in subsection 66.1(6).
XXXXXXXXXX.
"CRA" means the Canada Revenue Agency.
"Canadian resource property" has the meaning assigned by subsection 66(15).
"Declaration of Trust" means the amended and restated declaration of trust dated XXXXXXXXXX as amended by a supplemental declaration amendment dated XXXXXXXXXX and an amending agreement dated XXXXXXXXXX.
"Exchange XXXXXXXXXX" means the XXXXXXXXXX.
XXXXXXXXXX.
"Fiscal period" has the meaning assigned by subsection 249.1(1).
"FLP Loan" means the loan from LP2 to the Trust representing amounts that have been loaned by LP2 to the Trust, as described in paragraph 5 hereof.
"FLP2 Loan" means the loan from LP2 to ULC representing amounts that have been loaned by LP2 to ULC, as described in paragraph 5 hereof.
"GP1" means XXXXXXXXXX, a corporation incorporated under the CBCA. All of the issued and outstanding shares of GP1 are owned by the Partnership. GP1 is the managing general partner of LP1. The fiscal period of GP1 ends on XXXXXXXXXX.
"LLC" means XXXXXXXXXX, a limited liability company formed under the laws of the State of XXXXXXXXXX in the United States of America. All of the issued and outstanding membership interests in LLC are owned by the Trust.
"L-Royalty" means the gross royalty payable by XXXXXXXXXX of up to XXXXXXXXXX% of all of XXXXXXXXXX gross revenues on XXXXXXXXXX. L-Royalty is a "Canadian resource property".
"LP1" means the XXXXXXXXXX, a limited partnership formed under the Partnership Act (XXXXXXXXXX). The partners of LP1 are the Partnership as to a XXXXXXXXXX% general partnership interest, GP1 as to a XXXXXXXXXX% general partnership interest, and each of LP1 Partner 1 and LP1 Partner 2 as to a XXXXXXXXXX% limited partnership interest. LP1 Partner 1 and LP1 Partner 2 deal at arm's length with the Partnership and its partners. The fiscal period of LP1 ends on XXXXXXXXXX.
"LP1 Partnership Agreement" means the limited partnership agreement of LP1.
"LP1 Partner 1" means XXXXXXXXXX, a taxable Canadian corporation existing under the laws of XXXXXXXXXX that is wholly-owned by XXXXXXXXXX, a corporation incorporated under the laws of the State of XXXXXXXXXX in the United States of America. The fiscal period of LP1 Partner 1 ends on XXXXXXXXXX.
"LP1 Partner 2" means XXXXXXXXXX , a taxable Canadian corporation existing under the laws of XXXXXXXXXX that is indirectly wholly-owned by XXXXXXXXXX. The fiscal period of LP1 Partner 2 ends on XXXXXXXXXX.
"LP2" means the XXXXXXXXXX, a limited partnership formed under the Partnership Act (XXXXXXXXXX). The partners of LP2 are ULC as to a XXXXXXXXXX% general partnership interest and the Trust as to a XXXXXXXXXX% limited partnership interest. ULC is the general partner of LP2. The fiscal period of LP2 ends on XXXXXXXXXX.
"LP2 Interest" means the XXXXXXXXXX% limited partnership interest of the Trust in LP2.
"LP2 Partnership Agreement" means the amended and restated partnership agreement of LP2.
"Minority Partner 1" of the Partnership means the XXXXXXXXXX, a general partnership formed under the laws of XXXXXXXXXX, which owns a XXXXXXXXXX% partnership interest in the Partnership. The partners of Minority Partner 1 are XXXXXXXXXX as to a XXXXXXXXXX% partnership interest, and XXXXXXXXXX as to a XXXXXXXXXX% partnership interest. The fiscal period of Minority Partner 1 ends on XXXXXXXXXX. The fiscal periods of the partners of Minority Partner 1 end on XXXXXXXXXX.
"Minority Partner 2" of the Partnership means XXXXXXXXXX a general partnership formed under the laws of XXXXXXXXXX, which owns a XXXXXXXXXX% partnership interest in the Partnership. The partners of Minority Partner 2 are XXXXXXXXXX as to a XXXXXXXXXX% partnership interest, and XXXXXXXXXX as to a XXXXXXXXXX% partnership interest. The fiscal periods of Minority Partner 2 and its partners end on XXXXXXXXXX.
"Minority Partners" means Minority Partner 1 and Minority Partner 2. Each of the Minority Partners and its respective partners deals at arm's length with LP2 and the Trust.
"Mutual fund trust" has the meaning assigned by subsection 132(6).
"November 9, 2006 Amendments" means the amendments to the Act contained in the Notice of Ways and Means Motion dated November 9, 2006.
XXXXXXXXXX.
XXXXXXXXXX.
XXXXXXXXXX.
XXXXXXXXXX.
"Partnership" means the XXXXXXXXXX, a general partnership existing under the laws of XXXXXXXXXX. The partners of the Partnership are LP2 as to a XXXXXXXXXX% partnership interest, Minority Partner 1 as to a XXXXXXXXXX% partnership interest and Minority Partner 2 as to a XXXXXXXXXX% partnership interest. Minority Partner 1 is the managing partner.
"Partnership Agreement" means the amended and restated partnership agreement of the Partnership.
"Partnership Interest" means the XXXXXXXXXX% partnership interest in the Partnership held by LP2.
"Partnership Line of Credit" means the $XXXXXXXXXX line of credit which the Partnership uses from time to time:
(a) to pay for operating expenses and other obligations of the Partnership where it has insufficient cash;
(b) to make loans to its partners, as described in paragraph 12;
(c) XXXXXXXXXX; and
(d) XXXXXXXXXX.
Any debt arising from the line of credit is repaid out of cash from operations.
XXXXXXXXXX.
"Proposed Transactions" means the transactions described in section IV hereof.
"Reorganization" means the reorganization transactions contemplated in paragraphs 22 to 26.
"Resident" means a person who is a resident of Canada for the purposes of the Act.
"Royalty" means the net profits interest computed by reference to XXXXXXXXXX% of the production XXXXXXXXXX owned by the Partnership and by LP1 and of other cash flows generated within LP2 that will be created by LP2 and granted to the Trust by LP2, as described in paragraph 22 hereof.
"Royalty Agreement" means the royalty agreement that will govern the Royalty XXXXXXXXXX.
XXXXXXXXXX.
"Taxable Canadian corporation" has the meaning assigned by subsection 89(1).
"Taxable Canadian property" has the meaning assigned by subsection 248(1).
XXXXXXXXXX.
XXXXXXXXXX.
"Trust" means XXXXXXXXXX, a trust formed under the laws of XXXXXXXXXX pursuant to the Declaration of Trust. The principal office of the Trust is located at XXXXXXXXXX.
"Trust Note" means the promissory note issued by the Trust to LP2, as described in paragraph 22(a) hereof.
"Trustees" means the trustees of the Trust, all of whom are Residents.
"ULC" means XXXXXXXXXX, an unlimited liability company organized under the Companies Act (XXXXXXXXXX).
"ULC Shares" means all of the issued and outstanding common shares in the capital of ULC. The ULC shares are owned by LLC.
"Unit" means a unit representing a beneficial ownership interest in the Trust. Units are listed and posted for trading on Exchange XXXXXXXXXX.
"Unitholder" means a holder of one or more Units.
XXXXXXXXXX.
II FACTS
1. XXXXXXXXXX.
2. The Trust has a XXXXXXXXXX taxation year-end. It qualifies as a "unit trust" pursuant to paragraph 108(2)(a). The only undertakings of the Trust are a combination of the activities described in subparagraphs 132(6)(b)(i) and (ii) and the Trust qualifies as a mutual fund trust. The Trust was not established primarily for the benefit of persons who are not Residents and has not been maintained primarily for the benefit of persons who are not Residents. XXXXXXXXXX.
3. The principal property owned by the Trust is the LP2 Interest. Through its ownership of the LP2 Interest and the membership interests of LLC, the Trust owns directly and indirectly all of the partnership interests in LP2. The fair market value of the LP2 Interest represents more than XXXXXXXXXX% of the fair market value of all of the Trust's assets. The adjusted cost base of the LP2 Interest to the Trust as of XXXXXXXXXX is estimated to be $XXXXXXXXXX and its fair market value greatly exceeds its adjusted cost base.
4. The other material assets of the Trust are as follows:
XXXXXXXXXX.
5. LP2 has a loan receivable from each of the Trust (the "FLP Loan") and ULC (the "FLP2 Loan") which in each case represents the amounts that have been loaned by LP2 to the Trust and to ULC, as described in paragraph 16.
6. The Trust owes approximately $XXXXXXXXXX under the Bank Debt to a number of banks under a syndicated line of credit. The Partnership has provided a limited recourse guarantee in connection with the Bank Debt.
7. The Partnership operates XXXXXXXXXX.
8. Prior to XXXXXXXXXX, the Partnership also owned the XXXXXXXXXX.
9. XXXXXXXXXX.
10. The properties owned by the Partnership and LP1 include properties that qualify as XXXXXXXXXX and properties that qualify as XXXXXXXXXX, as those terms are defined for purposes of the Act.
11. XXXXXXXXXX.
12. XXXXXXXXXX.
13. XXXXXXXXXX.
14. XXXXXXXXXX.
15. XXXXXXXXXX.
16. XXXXXXXXXX.
17. All contributions to the capital of LP2 by the Trust and ULC have been and will up to and including the time of Reorganization be in proportion to their percentage partnership interests in LP2.
18. XXXXXXXXXX.
19. The Declaration of Trust provides that if the Trustees in their discretion determine that it is advisable and in the best interests of the Trust to take action so that the Trust will not cease to qualify as a mutual fund trust because of subsection 132(7), the Trustees may take one or more actions including the following:
XXXXXXXXXX.
20. The Trust has signed an exclusivity agreement and term sheet in relation to the sale of XXXXXXXXXX. Negotiations are ongoing but the sale, if perfected, is anticipated to be completed in XXXXXXXXXX.
21. The Trust currently has a CCDE balance of approximately $XXXXXXXXXX and a CCEE balance of approximately $XXXXXXXXXX.
IV PROPOSED TRANSACTIONS
To summarize, LP2 will create and grant a Royalty to the Trust which will be computed by reference to XXXXXXXXXX% of the production XXXXXXXXXX owned by the Partnership and by LP1 and of other cash flows generated within LP2. The Royalty will be paid by LP2 out of the proceeds of production XXXXXXXXXX that are received by LP2 as a partner of the Partnership, and out of the other cash flows received by LP2.
Reorganization Transactions
Transaction One
22. At XXXXXXXXXX, LP2 will create and grant the Royalty to the Trust.
(a) The sole consideration to be paid by the Trust for the Royalty will be an amount equal to the fair market value of the Royalty, which consideration will be satisfied by the issuance by the Trust to LP2 of an interest-free promissory note payable on demand with a principal amount and fair market value equal to the fair market value of the Royalty (referred to herein as the "Trust Note").
(b) The Trust Note will contain a price adjustment clause providing for self-adjustment to the fair market value of the Royalty (in consideration for which the Trust Note is issued) as of the time that the Royalty is created and granted.
(c) The Royalty will be created through a separate royalty agreement (the "Royalty Agreement") among the Trust and LP2. The Royalty will be a XXXXXXXXXX% interest in the net profits from the production XXXXXXXXXX owned by the Partnership and by LP1 and from other cash flows generated within LP2. The net profits will be computed by reference to the XXXXXXXXXX% interest that LP2 has XXXXXXXXXX owned by the Partnership and by reference to the XXXXXXXXXX% x XXXXXXXXXX% interest that LP2 has in XXXXXXXXXX owned by LP1, including, in both cases, XXXXXXXXXX acquired by the Partnership or by LP1 after the time that the Royalty is created. The Royalty will be paid by LP2 out of the proceeds of production XXXXXXXXXX that are received by LP2 as a partner of the Partnership, and out of the other cash flows received by LP2.
(d) The Royalty and the interest of the Trust in the Royalty will not be an interest in land or any type of real property interest.
The terms of the Royalty, which describe how the Royalty will be calculated and paid, are set out in the Royalty Agreement, XXXXXXXXXX.
Transaction Two
23. At some time in XXXXXXXXXX LP2 will compute its income for purposes of the Act for its fiscal period ending XXXXXXXXXX . LP2 will, pursuant to the LP2 Partnership Agreement, allocate to each of the Trust and ULC its share of such income, as described in paragraph 15. This allocation will be effective at the end of LP2's fiscal period ending XXXXXXXXXX.
Transaction Three
24. Effective at the end of its XXXXXXXXXX fiscal period, LP2 will allocate 100% of the proceeds of disposition of the Royalty to the Trust.
On XXXXXXXXXX, a new taxation year and fiscal period will commence for the Trust and for LP2, respectively.
Transaction Four
25. At XXXXXXXXXX, LP2 will distribute to the Trust a portion of the Trust's share of the income of LP2 for LP2's fiscal period ending XXXXXXXXXX, which portion will be an amount equal to the principal amount of the FLP loan as at the end of that fiscal period. The distribution will be accomplished by fully offsetting the amount of the distribution against the principal amount of the FLP Loan. The FLP Loan will be cancelled. The balance of the Trust's share of the income of LP2 for its XXXXXXXXXX fiscal period will be distributed in XXXXXXXXXX by way of a cash distribution after LP2's income for the fiscal period has been determined.
At XXXXXXXXXX, LP2 will distribute to ULC a portion of ULC's share of the income of LP2 for LP2's fiscal period ending XXXXXXXXXX, which portion will be an amount equal to the principal amount of the FLP2 loan as at the end of that fiscal period. The distribution will be accomplished by fully offsetting the amount of the distribution against the principal amount of the FLP2 Loan. The FLP2 Loan will be cancelled. The balance of ULC's share of the income of LP2 for its XXXXXXXXXX fiscal period will be distributed in XXXXXXXXXX by way of a cash distribution after LP2's income for the fiscal period has been determined.
Transaction Five
26. At XXXXXXXXXX,
(a) LP2 will distribute to the Trust the proceeds of disposition of the Royalty which will be accomplished by offsetting the obligation of the Trust to pay the Trust Note against the obligation of LP2 to make this distribution; the Trust Note will thereupon be cancelled; and
(b) LP2 will make a proportionate distribution to ULC by issuing to ULC a promissory note payable by LP2 to ULC with a principal amount equal to XXXXXXXXXX% of the fair market value of the Trust Note divided by XXXXXXXXXX%.
27. LP2, in computing its income in accordance with subsection 96(1) for its fiscal periods ending after XXXXXXXXXX, will deduct the payments made to the Trust under and pursuant to the Royalty.
V PURPOSE OF THE PROPOSED TRANSACTIONS
The purpose of the Proposed Transactions is to allow the Trust to fall within the exception provided in paragraph 132(7)(a) to the requirement in subsection 132(7) that a mutual fund trust must not be considered to have been established nor to be maintained primarily for the benefit of non-resident persons.
While the Trust was not established primarily for the benefit of non-resident persons, nor has it ever been maintained primarily for the benefit of non-resident persons, the Trustees are concerned that at some point the proportion of Units of the Trust held by non-resident persons could exceed the proportion of Units of the Trust held by Residents to an extent that it could cause uncertainty as to whether the Trust will be able to continue to qualify as a mutual fund trust. Whether or not this would occur is dependent on trading activity where the Units are listed for trading. The Trustees are not aware of any specific contemplated transaction that might occur to cause this result; nor are they able to control trading activity.
Nevertheless, if at some future time the Trustees believe that the non-resident ownership of the Units is such that it is possible that the Trust might reasonably be considered to be maintained primarily for the benefit of non-resident persons, they may cause the Trust to exercise one of the options described in paragraph 19 to reduce the proportion of non-resident owners, all of which options are costly and may cause a reduction in the trading value of the Units.
The Trust would therefore like to change the mix of property owned by it so that it can fall within the exception provided in paragraph 132(7)(a); that is, substantially all of its property, measured by fair market value, would be property that is not taxable Canadian property. It is proposed that this be accomplished by causing LP2 to grant a royalty XXXXXXXXXX in the manner described in this ruling request so that thereafter substantially all of the Trust's economic value would be inherent in the ownership of the Royalty. Because the Royalty would not qualify as taxable Canadian property, and because it would represent substantially all of the fair market value of the property owned by the Trust, subject to the comments that follow, the test in paragraph 132(7)(a) would be satisfied.
The current wording of paragraph 132(7)(a), however, requires that the "substantially all" test be met at all times from the creation of the trust. The Department of Finance has indicated in a letter dated November 26, 2004 that it is prepared to recommend to the Minister of Finance that paragraph 132(7)(a) be amended so that it would apply to a trust where, at a particular time, it could reasonably be considered to be maintained primarily for the benefit of non-residents but, at and after that time (and not from the time of creation), all or substantially all of the trust's property is property other than taxable Canadian property. Accordingly, the Trustees have agreed to cause LP2 to grant the Royalty to the Trust in the manner described in this ruling request. This would result in substantially all of the property of the Trust consisting of the Royalty which would be property other than taxable Canadian property.
VI RULINGS
Provided that the preceding statements constitute a complete and accurate disclosure of all the relevant facts, proposed transactions and purposes of the above transactions, and provided that the proposed transactions are completed in the manner described above, our rulings are as follows:
A. The Royalty, to be created and granted by LP2 to the Trust, as described in paragraph 22 hereof, will be a Canadian resource property by virtue of paragraph XXXXXXXXXX of the definition of "Canadian resource property".
B. At the time of the creation and grant by LP2 to the Trust of the Royalty, as described in paragraph 22 hereof:
(a) pursuant to subsection 98(2), LP2 will be deemed at that time to have disposed of Canadian resource property for proceeds of disposition equal to the fair market value of the Royalty;
(b) pursuant to subsection 98(2), the Trust will be deemed at that time to have acquired a Canadian resource property at a cost equal to the fair market value of the Royalty acquired by it;
(c) pursuant to paragraph XXXXXXXXXX of the definition of XXXXXXXXXX, the Trust will be regarded as incurring XXXXXXXXXX at that time in an amount equal to the cost of the Royalty acquired by it; and
(d) pursuant to XXXXXXXXXX, the Trust will immediately after that time add to its XXXXXXXXXX account an amount equal to the cost of the Royalty acquired by it; the addition to the Trust's XXXXXXXXXX account will therefore occur in its taxation year ending on XXXXXXXXXX.
C. The Trust will, pursuant to subsection XXXXXXXXXX, reduce its XXXXXXXXXX account for its taxation year in which the fiscal period of LP2 in which the Royalty is granted ends, by an amount equal to the share of LP2's proceeds of disposition for the Royalty that is allocated to the Trust by LP2, as described in paragraph 24.
D. Section 103 will not apply to the allocation of the proceeds of disposition of the Royalty by LP2 to the Trust.
E. Pursuant to subparagraph 53(1)(e)(i), immediately after LP2's fiscal period ending XXXXXXXXXX the adjusted cost base to the Trust of the LP2 Interest will be increased by the amount allocated to it as its share of the income of LP2 for that fiscal period ending XXXXXXXXXX, as described in paragraph 23.
Pursuant to subparagraph 53(2)(c)(v), immediately after the distribution made by LP2 to the Trust of an amount equal to the fair market value of the FLP Loan, as described in paragraph 25, the adjusted cost base to the Trust of the LP2 Interest will be reduced by the amount of that distribution.
F. Pursuant to subparagraph 53(1)(e)(viii), immediately after LP2's fiscal period ending XXXXXXXXXX the adjusted cost base to the Trust of the LP2 Interest will be increased by the amount allocated to it as the proceeds of disposition of the Royalty, as described in paragraph 24.
Pursuant to subparagraph 53(2)(c)(v), immediately after the distribution of the proceeds of disposition of the Royalty made by LP2 to the Trust of an amount equal to the fair market value of the Trust Note, as described in paragraph 26, the adjusted cost base to the Trust of the LP2 Interest will be reduced by the amount of that distribution.
G. Subsection 80.4(2) will not apply to the Trust in respect of the FLP Loan, FLP2 Loan or the Trust Note.
H. The "forgiven amount" for the purpose of section 80 in respect of the FLP Loan, FLP2 Loan and the Trust Note will, upon and following their cancellation as described in paragraphs 25 and 26, be nil.
I. In computing its income for a fiscal period ending after XXXXXXXXXX in accordance with the provisions of subsection 96(1), LP2 will be entitled to deduct all amounts that it has become obligated to pay in that fiscal period to the Trust under and pursuant to the terms of the Royalty, notwithstanding that actual payment of any such amount may occur in a subsequent fiscal period.
J. The Trust will be required to include in its income for each taxation year all amounts which it has become entitled to receive in that taxation year under and pursuant to the terms of the Royalty, notwithstanding that actual receipt of any such amount may occur in a subsequent taxation year.
K. For the purposes of subsection 132(7), the Royalty held by the Trust will not be considered to be taxable Canadian property.
L. Subsection 245(2) will not be applied as a result of the Proposed Transactions, in and of themselves, to redetermine any of the tax consequences confirmed in the Rulings requested herein.
The above rulings are based on the Act in its present form and do not take into account any proposed amendments to the Act. Nothing in this ruling should be construed as implying that the CRA has agreed to or reviewed any tax consequences relating to the facts and Proposed Transactions described herein other than those described in the rulings given.
These rulings are given subject to the limitations and qualifications set forth in Information Circular 70-6R5 issued on May 17, 2002 and are binding on the CRA provided that the Proposed Transactions are completed within six months of the date of this letter.
VII OPINION
Provided that draft paragraph XXXXXXXXXX of the definition of "Canadian resource property" in subsection 66(15) is enacted in substantially the same form as proposed in the November 9, 2006 Amendments, the Royalty to be created and granted by LP2 to the Trust, as described in paragraph 22 hereof, will be a Canadian resource property by virtue of paragraph XXXXXXXXXX of that definition.
Yours truly,
Director
International and Trusts Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch
XXXXXXXXXX
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