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Principal Issues: Where an income distribution reinvestment plan of a unit trust enables a unitholder to reinvest income distributions in new units at a price equal to XXXXXXXXXX % of the average market price and without commission or service charge, will a benefit be considered to be conferred pursuant to subsection 105(1)? ...

Yours truly, for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

It is anticipated that XXXXXXXXXX other First Nations located in XXXXXXXXXX will become limited partners of LP1 and will each acquire a XXXXXXXXXX % interest in the partnership. ...

To the best of your knowledge, and that of the taxpayer involved, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayer 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 taxpayer or a related person; (iii) under objection by the taxpayer 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. ...

Immediately after the Shares are issued under the proposed transaction, Annuitants will own (and will be deemed to own by virtue of the definition of "specified shareholder" in subsection 248(1), paragraphs (a) and (b)) Shares as follows: RRSP Shareholders Fraction of Share Owned % Company Owned XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX PURPOSE OF THE PROPOSED TRANSACTION 13. ...

In this letter, the following terms have the meanings specified: (a) "Act" means the Income Tax Act, R.S.C 1985 (5th Supp.) c.1, as amended to the date hereof, and, unless otherwise stated, every reference herein to a Part, section, subsection, paragraph or subparagraph is a reference to the relevant provision of the Act; (b) "Canadian resource property" has the meaning assigned by subsection 66(15); (c) "CCOGPE" means "cumulative Canadian oil and gas property expense" within the meaning assigned by subsection 66.4(5); (d) "COGPE" means "Canadian oil and gas property expense" within the meaning assigned by subsection 66.4(5); (e) "GOR agreement " means the agreement described in paragraphs 5, 6 and 7 below between Petroleum Co. and the resource company, and which will be substantially similar to the Royalty Agreement dated XXXXXXXXXX that was provided with your advance income tax ruling request; (f) "Grantor of the GOR agreement" is the resource company that is party to the GOR agreement with Petroleum Co.; and (g) "Petroleum Co. ...

Principal Issues: Variation of a trust with unborn beneficiaries- can a Saunders & Vautier variation be made? ...

In addition, lock-up agreements (which the parties called "Voting Agreements") were entered into at various times on or before XXXXXXXXXX between (i) Buyco and Holdco, and (ii) XXXXXXXXXX shareholders and/or optionholders of Target who, in the aggregate, hold approximately XXXXXXXXXX % of the shares of Target, but none of whom individually owns, directly or indirectly, or exercises control over, more than 10% of the common shares of Target. ...

These rulings are given subject to the limitations and qualifications set forth in Canada Customs & Revenue Agency (the "Agency") Information Circular 70-6R3 dated December 30, 1996, and are binding upon the Agency provided the Plan is implemented on or before XXXXXXXXXX. ...

Yours truly, XXXXXXXXXX for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...