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Effect of Paragraph l(2)(c) of EIA for Income Tax Purposes Paragraph l(2)(c) of the EIA provides as follows: (2) For the purposes of this Act (...) ...

XXXXXXXXXX There are XXXXXXXXXX FCo XXXXXXXXXX Shares; “eligible property” has the meaning assigned by subsection 85(1.1); “ First Act ” means the Canada Business Corporations Act; “First Exchange” means XXXXXXXXXX; “forgiven amount” has the meaning assigned by subsections 80(1) and 80.01(1); “Fund Trustees” means a group of XXXXXXXXXX persons who will be elected by Unitholders in accordance with the Fund Declaration of Trust to act as trustees of New Fund, subject to the terms of the XXXXXXXXXX Agreement. ...

This ruling replaces and rescinds Ruling # 2000- 004652, dated XXXXXXXXX, 2001. ...