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No Reasons: Please refer to the analysis in the document March 22, 2001 INTERNATIONAL TAX DIRECTORATE HEADQUARTERS Transfer Pricing & Alison Campbell Competent Authority Attention: Tam Nguyen 2000-004916 XXXXXXXXXX Canadian Investment Fund- Unregistered Reinsurance Reserve XXXXXXXXXX Taxation Years (Your File XXXXXXXXXX) This is in reply to your memorandum of September 25, 2000, regarding the XXXXXXXXXX and its Canadian branch, hereinafter referred to as USCo and the Branch, respectively. ...

The only remaining property will be Series 2 shares and Company A will receive XXXXXXXXXX % of the remaining Series 2 shares and the limited partners of LP A will receive XXXXXXXXXX% of the remaining Series 2 shares, in proportion to the number of such limited partnership units held. ...

Subco1's authorized share capital will include at least one class of voting common shares and Class "A" shares which will be non-voting, non-participating preferred shares bearing a discretionary non-cumulative dividend of up to XXXXXXXXXX % per month and redeemable at the option of the corporation or shareholder for an amount equal to the fair market value of the amount received by the corporation as consideration for the share. ...

The purpose test in 104(7.1) is not met, namely the main purpose of the proposed transactions is to reduce the administrative complexity of the Reduced Management Fee program & to enable the manager to effectively market the units to differing groups of Investors. ...

., as part of the public offering, will purchase and hold, at the outset, XXXXXXXXXX % of the issued MFT units. ...

Newco will add to the stated capital account maintained for its Newco Preferred Shares an amount equal to the amount by which the aggregate of: (a) the cost amounts, in the case of eligible properties, (b) the fair market value, in the case of other properties, and (c) the amount of the XXXXXXXXXX/Aco Promissory Note 2 transferred to XXXXXXXXXX/Bco exceeds (d) the amount equal to XXXXXXXXXX % of the Liabilities assumed by Newco. 20. ...

Propertyco also owns a XXXXXXXXXX % co-ownership interest (the "Interest") in XXXXXXXXXX lands, facilities and chattels and related inventories, accounts receivable and deposits (collectively, the "Facility”) that Propertyco and an arm's length third party (XXXXXXXXXX, or the “Co-owner") hold as equal tenants-in-common. ...

OPCO owns, inter alia, XXXXXXXXXX% of the shares of XXXXXXXXXX ("XXXXXXXXXX CO "), a company incorporated under the laws of XXXXXXXXXX and engaged in marketing, distributing and selling Products for the U.S. ...

Y will be equal to or approximate the amount determined by the formula (A x B/C) + D as found in subparagraph (b)(iii) of the definition of "permitted exchange" in subsection 55(1). ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (i) dealt with 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 the taxpayers or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...