1999 Ruling 9919863 - SUPPLEMENTARY

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 Department.

Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère.

XXXXXXXXXX
XXXXXXXXXX 1-991986
XXXXXXXXXX

Attention: XXXXXXXXXX

XXXXXXXXXX, 1999

Dear Sirs:

Re: XXXXXXXXXX
Advance Income Tax Ruling

This is in reply to your letter of XXXXXXXXXX, in which you advised us of changes to the proposed transactions, rulings and comments described in our letter of XXXXXXXXXX, 1999 on our file number 3-991397 (the "Ruling"). You also requested that we confirm that facts, represented in paragraphs 15, 16, 17, 18, 19 and 20 of the Ruling to be accurate as at XXXXXXXXXX, may have changed between XXXXXXXXXX and the date of the Ruling and that this will not affect the rulings given in the Ruling. (Terms defined in the Ruling to have a certain meaning have the same meaning when used in this letter.)

As a result of your letter the following changes are made to the Ruling:

1. Paragraph 30, line 2, delete the word "consists" and replace with the word "consist".

2. Paragraph 31, line 3, following the words "at that time" add the words "and pay such amount per share to holders of SVS and MVS as a return of capital".

3. Paragraph 32, delete and replace with the following:

"32. In addition, XXXXXXXXXX will declare and pay a dividend of approximately $XXXXXXXXXX per share to each holder of a SVS or MVS."

4. Delete Ruling D.

5. In the Comments paragraph, line 1, delete the words "Ruling D" and replace with the words "paragraph 32".

We confirm that the above changes and deletion of Ruling D will not affect the remaining rulings given in the Ruling and the remaining rulings will continue to be binding as indicated therein.

Yours truly,

for Director
Reorganization and International Division
Income Tax Rulings and
Interpretations Directorate
Policy and Legislation Branch