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More particularly, the Partners are as listed in your XXXXXXXXXX, letter to us and are XXXXXXXXXX (n) "Partnership" means the partnership, which currently carries on the Practice under the firm name and style of "XXXXXXXXXX ". ... Each Partner currently works approximately the same number of hours, except for a few who work less hours and are only entitled to XXXXXXXXXX % of a full share of the net profits of the Partnership. ...

Yours truly, XXXXXXXXXX Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch APPENDIX A- PROPERTY 1 XXXXXXXXXX APPENDIX B- PROPERTY 2 XXXXXXXXXX APPENDIX C- PROPERTY 3 XXXXXXXXXX APPENDIX D – PROPERTY 4 XXXXXXXXXX APPENDIX E- PROPERTY 4 XXXXXXXXX ...

Following this distribution, Newco will have at least XXXXXXXXXX shareholders holding Class A Shares having a fair market value of at least $XXXXXXXXXX, and insiders of Newco will hold less than XXXXXXXXXX % of the issued and outstanding Class A Shares. ... Yours truly, XXXXXXXXXX Section Manager For Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

The amount of the taxable dividend paid by Amalco was approximately $ XXXXXXXXXX. 26. ... The amount of the PUC reduction was approximately $ XXXXXXXXXX. For greater certainty, the payment on the PUC reduction did not exceed the aggregate PUC or aggregate ACB of the Canco Preferred Shares to NRco D. 27. ...

The authorized capital of each of the Newcos will consist of: (a) an unlimited number of voting common shares; (b) an unlimited number of Class A non-voting, redeemable and retractable special shares ("Newco Class A Special Shares"), bearing a non-cumulative dividend rate of XXXXXXXXXX % per annum on the redemption price; and (c) an unlimited number of Class B non-voting, redeemable and retractable special shares ("Newco Class B Special Shares"), bearing a non-cumulative dividend rate of XXXXXXXXXX % per annum on the redemption price. ...

XXXXXXXXXX Holdco owns XXXXXXXXXX % of the issued and outstanding shares of XXXXXXXXXX. 27. ... Yours truly, XXXXXXXXXX Section Manager For Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

The amount to be added to the stated capital of the Newco4 class A common shares so issued will be an amount equal to the aggregate adjusted cost base of the common shares of Pubco so transferred (the "Transferred Shares "4 ""). 15. ... Jco will designate, in respect of the Transferred Shares "1", the Transferred Shares "2", the Transferred Shares "3" and the Transferred Shares "4"in its income tax return of income for the taxation year in which each of Newco1, Newco2, Newco3 and Newco4 is wound up, an amount pursuant to paragraph 88(l)(d), equal to the difference between: (a) the purchase price paid by Jco for the shares of Newco1, Newco2, Newco3 and Newco4, as the case may be, as described in paragraph 16 above; and (b) the adjusted cost base to Newco1, Newco2, Newco3 and Newco4, as the case may be, of the Transferred Shares "1", the Transferred Shares "2", the "Transferred Shares "3", and the "Transferred Shares "4" (hereinafter sometimes collectively referred to, together with the "Transferred Shares "A" and the "Transferred Shares "B", as the "Transferred Shares "), as the case may be, as a result of the transaction described in paragraph 14 above. 19. ...

Principal Issues: • butterfly ruling- similar to other given in past Position:- favorable ruling given Reasons: no new issues XXXXXXXXXX 962858 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 1997 Dear Sir/Madam: Re: XXXXXXXXXX Advance Income Tax Ruling We are writing in response to your letter of XXXXXXXXXX wherein you requested an advance income tax ruling on behalf of the above referenced taxpayers. ... The issued and outstanding shares of DC are as follows: Class & Number Shareholder of Shares PUC ACB XXXXXXXXXX The shares of DC represent capital property to each of the shareholders referred to above. ...

The details of the Mortgage Loans and the Operating Lines (collectively, the "Loans"), totalling approximately $XXXXXXXXXX, which are owed to the Lenders and which the Debtor proposes to refinance with preferred shares are as follows and as described in 11 below: LENDER PROPERTY INTEREST RATE PRINCIPAL % AMOUNT XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX 11. The principal amounts as of XXXXXXXXXX, and interest rates (XXXXXXXXXX) on the Operating Lines with Lender A are as follows: PRINCIPAL AMOUNT INTEREST RATE RATE EXPIRY DATE % XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX 12. ...

Reasons: XCO will own XXXXXXXXXX % of the voting shares of Aco and will not have de-jure control. ... Aco will transfer its intellectual property, remaining cash and fixed assets, other than the building XXXXXXXXXX (the "XXXXXXXXXX Building"), to PartnershipB and as consideration therefor, PartnershipB will assume all of Aco's liabilities, XXXXXXXXXX its bank loan, and issue to Aco a limited partnership interest and a general partnership interest entitling it to XXXXXXXXXX % and XXXXXXXXXX% of the income or loss of PartnershipB, respectively. ...