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" 2. The following sentence is added following the first sentence of Paragraph 66.1: " At that time, Amalco will also transfer some minor furniture and fixtures to Employeeco. " 3. Paragraph 67 is amended to read as follows: " Amalco will effect a series of increases in the stated capital of the Amalco Class XXXXXXXXXX Preference Shares, the aggregate amount of which will be equal to a portion of the balance in Amalco's CDA immediately before the time of the commencement of such stated capital increases. ... Yours truly, for Director Reorganizations and Resources Division Income Tax Rulings Directorate Policy and Legislation Branch ...

Welcome to the Income Tax Rulings & Interpretations Directorate Bulletin Board. ... Bouffard 957-2130 Michael Cooke 957-3498 Ghislaine Landry 957-9229 Roxane Brazeau- LeBlond 957-2058 CORPORATE FINANCING SECTION BUSINESS & PROPERTY INCOME AND EXEMPT ORGANIZATIONS SECTION Wayne Douglas, Chief 957-8957 Roberta Albert, A/Chief 957-2100 Fiona Francis 957-8971 Murray Brake 957-2133 Peter Dunn 957-2747 John Brooks 957-2103 Steve Tevlin 957-2746 Bill Guglich 957-2102 Claude Tremblay 957-2744 Carole Chouinard 957-2098 Mary Pat Baldwin 957-2745 Bill Kerr 957-2139 Milled Azzi 957-8972 DEFERRED INCOME PLANS SECTION PERSONAL & GENERAL SECTION Acting Chief 957-8979 John Oulton, Chief 957-2049 Wayne Harding 957-9769 Danielle Zion 957-2140 David Duff 957-8979 Marv Eisner 957-2138 Patricia Spice 952-8984 Annemarie Humenuk 957-2134 Mickey Sarazin 957-3499 Jack Szeszycki 957-2135 Frank Gillman 952-9853 Sandra Short 957-2136 SECTION DU FINANCEMENT, TECHNICAL PUBLICATIONS SECTION ET DES RÉGIMES Tim Bryant, A/Chief 957-2052 Jean-Guy Aubé, Chief 957-8963 Fay Bisailion 952-1361 Ghislain Martineau 957-8962 Gwen Moore 952-1506 Maureen-Shea- Rick Primeau 957-2060 DesRosiers 957-8961 Jim McFarlane 957-2087 Adèle St-Amour 952-1764 Louise Roy 957-2092 FIELD LIAISON & TECHNICAL PROJECTS SECTION Paul Lynch, A/Chief 957-8973 Bruce Rankin 952-3606 Ron Lefebvre 957-0682 Shirley Sarrazin 957-2137 Jackie Page 957-0682 RESOURCES, REORGANIZATIONS AND PARTNERSHIPS AND TRUSTS DIVISION INTERNATIONAL DIVISION R. ... Plant 957-2120 George Keable 957-2046 TECHNICAL REVIEW & REMISSIONS SECTION Bill McCcColm, Chief 957-9226 Ed Campbell 957-2053 Martine Filiatrault 952-5803 Sandy Parnanzone 957-9232 Kevin Donnelly 957-2082 Jacques Grisé 957-2059- 7-- 10-... ...

Welcome to the Income Tax Rulings & Interpretations Directorate Bulletin Board. ... UNFUNDED PENSION LIABILITIES & UNFUNDED HEALTH & WELFARE PLANS We refer to document 951517 for a discussion on this issue. ... Bouffard) LEASING & FINANCING SECTION BUSINESS & PROPERTY INCOME AND EXEMPT ORGANIZATIONS SECTION Wayne Douglas, Chief 957-8957 Roberta Albert, A/Chief 957-2100 Fiona Francis 957-8971 Murray Brake 957-2133 Peter Dunn 957-2747 John Brooks 957-2103 Steve Tevlin 957-2746 Bill Guglich 957-2102 Claude Tremblay 957-2744 Carole Chouinard 957-2098 Mary Pat Baldwin 957-2745 Bill Kerr 957-2139 Les Barrows 952-1361 Milled Azzi 957-8972 DEFERRED INCOME PLANS SECTION PERSONAL & GENERAL SECTION Vacant 957-8979 Paul Fuoco, Chief 957-2141 Wayne Harding 957-9769 Danielle Zion 957-2140 David Duff 957-8968 Marv Eisner 957-2138 Patricia Spice 952-8984 Annemarie Humenuk 957-2134 Mickey Sarazin 957-3499 Jack Szeszycki 957-2135 F. ...

Welcome to the Income Tax Rulings & Interpretations Directorate Bulletin Board. ... UNFUNDED PENSION LIABILITIES & UNFUNDED HEALTH & WELFARE PLANS We refer to document 951517 for a discussion on this issue. ... Bouffard) LEASING & FINANCING SECTION BUSINESS & PROPERTY INCOME AND EXEMPT ORGANIZATIONS SECTION Wayne Douglas, Chief 957-8957 Roberta Albert, A/Chief 957-2100 Fiona Francis 957-8971 Murray Brake 957-2133 Peter Dunn 957-2747 John Brooks 957-2103 Steve Tevlin 957-2746 Bill Guglich 957-2102 Claude Tremblay 957-2744 Carole Chouinard 957-2098 Mary Pat Baldwin 957-2745 Bill Kerr 957-2139 Les Barrows 952-1361 Milled Azzi 957-8972 DEFERRED INCOME PLANS SECTION PERSONAL & GENERAL SECTION Vacant 957-8979 Paul Fuoco, Chief 957-2141 Wayne Harding 957-9769 Danielle Zion 957-2140 David Duff 957-8968 Marv Eisner 957-2138 Patricia Spice 952-8984 Annemarie Humenuk 957-2134 Mickey Sarazin 957-3499 Jack Szeszycki 957-2135 F. ...

Papineau Chief, Equal Pay Section Classification, Human Resources J.D. ... Dath Director Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch Document Disclosed Pursuant to the Access to Information Act Document Divulgué en vertu de la loi sur l'accès à l'informationLANGIND E DOCNUM ACC9198 REPLACES TYPEKEY R AUTHORDV LEGS AUTHOR TMURPH DESCKEY 6 RATEKEY 1 REFDATE 900323 ETADYEAR ETADSORT ADMINACC LEGS ACCESSLV LEGS99 SUBJECT Tax Executive Institute's questions — zero coupon bonds, low interest loans, term preferred shares, leasing property rules SECTION ITA-20(1)(c), 20(1)(d) SECTION SECTION SECTION SECTION $$$$ March 23, 1990 R.J.L. ...

Welcome to the Income Tax Rulings & Interpretations Directorate Bulletin Board. ... UNFUNDED PENSION LIABILITIES & UNFUNDED HEALTH & WELFARE PLANS We refer to document 951517 for a discussion on this issue. ... Bouffard LEASING & FINANCING SECTION BUSINESS & PROPERTY INCOME AND EXEMPT ORGANIZATIONS SECTION Wayne Douglas, Chief 957-8957 Roberta Albert, A/Chief 957-2100 Fiona Francis 957-8971 Murray Brake 957-2133 Peter Dunn 957-2747 John Brooks 957-2103 Steve Tevlin 957-2746 Bill Guglich 957-2102 Claude Tremblay 957-2744 Carole Chouinard 957-2098 Mary Pat Baldwin 957-2745 Bill Kerr 957-2139 Les Barrows 952-1361 Milled Azzi 957-8972 DEFERRED INCOME PLANS SECTION PERSONAL & GENERAL SECTION Paul Fuoco, Chief 957-2141 Wayne Harding 957-9769 Danielle Zion 957-2140 David Duff 957-8968 Marv Eisner 957-2138 Patricia Spice 952-8984 Annemarie Humenuk 957-2134 Mickey Sarazin 957-3499 Jack Szeszycki 957-2135 Frank Gillman 952-9853 Sandra Short 957-2136 SECTION DE FINANCEMENT, LOCATION ET DES RÉGIMES Jean-Guy Aubé, Chief 957-8963 Ghislain Martineau 957-8962 Maureen-Shea- DesRosiers 957-8961 Adèle St-Amour 952-1764 Louise Roy 957-2092 MANUFACTURING INDUSTRIES, REORGANIZATIONS AND PARTNERSHIPS AND TRUSTS DIVISION FOREIGN DIVISION R. ...

However, in view of the costs of these committees in terms of time and resources and the experience gained by the Department in administering the fairness provisions, it is suggested that such committees now be used on a more selective basis to consider only the following type of items: • complex, precedent setting, sensitive or higher dollar requests. • requests for a second review of items denied at the first level of supervision (See comments below on the approval/denial process). • requests based on an inability to pay involving more than ***in penalty and/or interest. ... These requests include: • Complex cases of a sensitive or precedent setting nature or those which involve decisions affecting multiple jurisdictions (local, regional or national cases). • High dollar items. ... Delegation of Authority *** *** *** Organizational Roles/Responsibilities Systems Development Requests for fairness relief may be received and actioned by many different divisions and at varying levels within the organization. ...

Thomson (613) 957-2122 Attention: Joe MacDonald Technical Resource Officer 2002-013563 Payment from XXXXXXXXXX This is in reply to your memo to us on April 15, 2002, on behalf of XXXXXXXXXX letter was sent to you by the XXXXXXXXXX TSO. ... We would tend to agree with this characterization, based on the information we have been able to obtain.The courts have said that damages must be considered in light of the purpose and the effect of the action in which they were awarded (). ... Yours truly, Olli Laurikainen Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch ...

PRINCIPAL ISSUES: whether revisions to proposed transactions would have any impact on rulings given POSITION: no REASONS: revisions are inconsequential XXXXXXXXXX 2005-016314 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: XXXXXXXXXX Advance Income Tax Ruling No. 2005-013289 [] This is in reply to your letter of XXXXXXXXXX wherein you advised of us certain amendments to the proposed transactions described in advance income tax ruling 2005-013289 [2005-0132891R3] (the “Ruling Letter”) that was issued on XXXXXXXXXX, 2005. ... Yours truly, for Director Reorganizations and Resources Division Income Tax Rulings Directorate Policy and Planning Branch ...

Cameron April 26, 1994 940958 Question Question 18 for the round table at the May 1994 meeting of the Institute of Chartered Accountants of Alberta concerned a situation where all of the assets of a partnership, which are composed primarily of Canadian resource properties and related tangibles, will be distributed in a manner such that each partner receives a pro-rata undivided interest therein immediately prior to the dissolution of the partnership. ... (It should be noted that these questions were submitted for the 1993 CPTS Conference but were not answered at that time; the response to the first question is identical to that prepared at that time- see memo dated December 7, 1993, file # 931692.) ...