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The Return will be determined according to the following formula: Return = (Principal Amount x Percentage Change x Participation Rate) 7. ...

DEFINITIONS In this letter, all monetary amounts are expressed in Canadian dollars unless otherwise indicated, and the following terms or expressions have the meaning specified: (a) "Act" means the Income Tax Act, R.S.C. 1985 (5th Supp.) c.1, as amended from time to time and consolidated to the date of this letter, and unless otherwise expressly stated, every reference herein to a part, section or subsection, paragraph or subparagraph, clause or subclause is a reference to the relevant provision, and the Income Tax Act Regulations thereunder are referred to as the "Regulations"; (b) "adjusted cost base " has the meaning assigned by section 54; (c) "affiliated persons" has the meaning assigned by subsection 251.1(1); (d) "BCA1" means the Canada Business Corporations Act; (e) "BCA2" means the XXXXXXXXXX; (f) "BN" means the tax identification number assigned by the CRA to the particular entity; (g) "Canco" means XXXXXXXXXX; (h) "CRA" means the Canada Revenue Agency; (i) "fair market value" means the highest price amount available in an open and unrestricted market between informed prudent parties acting at arm's length; (j) "Forco1" means XXXXXXXXXX; (k) "Forco2" means XXXXXXXXXX; (l) "Lossco" means XXXXXXXXXX; (m) "non-capital loss" has the meaning assigned by subsection 111(8); (n) "paid-up capital" has the meaning assigned by subsection 89(1); (o) "Paragraph" means a numbered paragraph in this advance tax ruling; (p) "Profitco" means XXXXXXXXXX; (q) "Proposed Transactions" means the transactions described in Paragraphs 11 to 12; (r) "public corporation" has the meaning assigned by subsection 89(1); (s) "related persons" has the meaning assigned by section 251; (t) "subsidiary wholly-owned corporation" has the meaning assigned by subsection 248(1); (u) "taxable Canadian corporation" has the meaning assigned by subsection 89(1); and (v) "taxation year" has the meaning assigned by subsection 249(1). ...

À titre indicatif, vous nous mentionnez que la juste valeur marchande de l'Œuvre serait de XXXXXXXXXX $. ...

Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

The construction of the Facility is expected to last for a period of approximately XXXXXXXXXX years; (e) "Contract Period" is the period that includes the Construction Period and the Operating Period and is expected to last for a period of XXXXXXXXXX years; (f) "Contractor" means the joint venture between XXXXXXXXXX (a wholly-owned subsidiary of Z Co) and XXXXXXXXXX that will design and build the Project under an EPC Contract with the Partnership; (g) "CRA" means Canada Revenue Agency; (h) "Entity " is the XXXXXXXXXX; (i) "EPC Contract" means the engineering, procurement and construction contract between the Partnership and the Contractor; (j) "Facility" is the proposed XXXXXXXXXX; (k) "GP" is XXXXXXXXXX; (l) "Licence" is the non-exclusive licence that the Province will grant to the Partnership, pursuant to the Concession Agreement, to provide the Partnership with rights of use and access to the Site and the Facility, for the purposes of constructing the Facility and providing services during the Operating Period; (m) "Loan Agreement" is the agreement between XXXXXXXXXX and XXXXXXXXXX (collectively the "Lenders"), the Partnership, and GP pursuant to which the Lenders will make a loan to the Partnership; (n) "Operating Period" is the part of the Contract Period that begins immediately after the Construction Period and ends at the end of the Contract Period; (o) "Partnership" is a limited partnership formed under the laws of XXXXXXXXXX called the XXXXXXXXXX, with Z Co as the limited partner and XXXXXXXXXX as the general partner; (p) "Project" is the XXXXXXXXXX; (q) "Province" is the Province of XXXXXXXXXX; (r) "Site" is the land on which the Facility will be constructed; (s) "Substantial Completion" means the substantial completion of the construction of the Facility as outlined in the Concession Agreement; (t) "Taxable Canadian corporation" has the meaning assigned by subsection 89(1) of the Act; (u) "TSO" means Tax Services Office; and (v) "Z Co" is XXXXXXXXXX. ...

Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

Principal Issues: Whether proposed foundation for R & D in XXXXXXXXXX qualifies under 149(1)(j) Position: Limited ruling provided that it will be considered the be constituted exclusively for the purpose of carrying on or promoting SR&ED for the purposes of 149(1)(j). ...

Principal Issues: 1)whether 254(a) applies to the purchase by an RCA trust of annuities providing periodic payments for life & a lump sum for guaranteed portion for the spouse of a deceased employee; 2)whether the employer may loan (i.e. it won't be considered a contribution) the amount needed by the RCA trust to make up the difference between the RCA assets and the price of the annuities (loan to be repaid by the amount of refundable tax the refund of which is triggered by the purchase of the annuities); 3)whether the annuities will be considered subject property of the RCA thereby preventing refund of Part XI.3 tax to custodian after final return filed. ...

Reasons: 1) & 2) Routine- see E9700303. XXXXXXXXXX 970029 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 1997 Re: Advance Income Tax Ruling XXXXXXXXXX Incentive Compensation Arrangement This is in reply to your letters of XXXXXXXXXX, in which you request an advance income tax ruling on behalf of the above-named taxpayer, and further to our telephone conversations XXXXXXXXXX. ...

Sale at FMV after acquisition would result in no gain. 2.Purpose and use of borrowing is to acquire pref shares of Acquisitionco having a dividend rate > interest rate on borrowing. ...