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Yours truly, XXXXXXXXXX, Manager For Director International & Trusts Division Income Tax Rulings Directorate ...

Yours truly, XXXXXXXXXX Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

The members of the Second Partnership derive XXXXXXXXXX %, of their Professional Services income from the Second Partnership. ...

Yours truly, XXXXXXXXXX Acting Manager, Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

Collectively they are referred to as the "Partners"; (o) "Partnership" means the partnership, which currently carries on the Practice under the firm name "XXXXXXXXXX ". ...

For purposes of this paragraph, " family" means individuals connected by blood relationship, marriage, common-law partnership or adoption, as those terms are described in subsection 251(6) of the Act. 15. ...

There are, however, certain matters which require a XXXXXXXXXX % majority vote to pass. k) The day-to-day management and affairs of the Partnership is carried out by the Management Committee. l) A Named Partner shall retire and terminate all of its interest in the Partnership at the end of the year after the Principal of the Named Partner becomes XXXXXXXXXX years of age, but the Partnership shall not dissolve. m) Upon leaving the Partnership, the Principal of a Named Partner is subject to a non-competition and non-solicitation covenant for a period of XXXXXXXXXX years. n) Upon leaving the Partnership, a Named Partner is entitled to be paid certain amounts including his balance in the capital account, and his share of the Distributable Net Income of the Partnership for the year in which the withdrawal occurs. 9. ...

., a corporation incorporated under the XXXXXXXXXX that carries on business under the name 'XXXXXXXXXX '; (f) "Beneficiaries" means the residual beneficiaries of the Estate described in Paragraph 8; (g) "Canadian-controlled private corporation" or "CCPC" has the meaning assigned by subsection 125(7); (h) "capital property" has the meaning assigned by section 54; (i) "Cco" means XXXXXXXXXX., a corporation incorporated under the XXXXXXXXXX (j) "Child 1" means XXXXXXXXXX of X; (k) "Child 2" means XXXXXXXXXX of X; (l) "Child 3" means XXXXXXXXXX of X; (m) "Child Note" means a promissory note of Newco with a fair market value and face amount equal to XXXXXXXXXX of the adjusted cost base of the shares of Holdco to the Estate as determined under subsection 84.1(2) for the purposes of the transfer described in Paragraph 15. ...

The Partnership may also contract with other XXXXXXXXXX from time to time (generally referred to as "XXXXXXXXXX "). ...

More particularly, the Partners are as listed in Appendix 'A', attached to this letter; (n) "Partnership" refers to the existing partnership of "XXXXXXXXXX ", which was formed pursuant to the laws of the Province of XXXXXXXXXX; (o) "Partnership Agreement" refers to the partnership agreement for the Partnership made between the Partners, as approved by the Partners on XXXXXXXXXX, practicing as a XXXXXXXXXX and as a partnership, as more fully described in Paragraph 5; (p) "personal services business" has the meaning assigned by subsection 125(7) of the Act; (q) "Practice" means the services currently provided by the Partnership, being the provision of Professional Services and also includes the Administrative Responsibilities conducted by the Partners that are necessary to carry on the professional practice; (r) "Professional Services" means the professional services of the practice of XXXXXXXXXX; (s) "Proposed Transactions" means the transactions described in Paragraphs 6 to 14; (t) "Provinces" means the provinces of XXXXXXXXXX; (u) "Regulatory Body" means XXXXXXXXXX; (v) "related person" has the meaning assigned by section 251 of the Act; (w) "specified partnership income" has the meaning assigned by subsection 125(7) of the Act; and (x) "TCC" has the meaning of "taxable Canadian corporation" assigned by subsection 89(1) of the Act. ...