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2002 Ruling 2002-0167263- CHANGES TO TERMS OF DEBT & CONSEQUENCES Unedited CRA Tags 212(1)(b)(vii) 20(1)(f) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... (b) Whether the cash amount paid in satisfaction of the XXXXXXXXXX % Interest is deductible under paragraph 20(1)(f)? ... (k) The Fair Market Value of the XXXXXXXXXX% Interest may be determined by an investment banker of a national standing in Canada experienced in XXXXXXXXXX businesses; Note that the XXXXXXXXXX % interest is also payable upon the redemption of the Debentures because of the definition of "Redemption Amount" (see definition above) which refers to the XXXXXXXXXX % interest. ...

2001 Ruling 2001-0067513- Inducement Payment & ACB of Shares Unedited CRA Tags 12(1)(x) 53(2.1) 53(2)(s) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... These rulings are provided subject to the limitations and qualifications set out in Information Circular 70-6R4 issued by the Canada Customs & Revenue Agency on January 29, 2001 and are binding upon the Agency provided that the proposed transactions are completed on or before XXXXXXXXXX. ...

2008 Ruling 2008-0295711R3- Indian Band-Public Body & Function of Government Unedited CRA Tags 149(1)(c) Principal Issues: Is the Indian band a public body performing a function of government? ... This GIC will earn interest at a rate of XXXXXXXXXX %. Purpose of the Proposed Transaction The purpose of the proposed transaction is to generate additional income for the Indian Band to fund and support the governance, public works, infrastructure, social services and general development of the Indian Band. ...

2009 Ruling 2009-0336261R3- transferable warrants & flow through shares Unedited CRA Tags 66(15); 66(12.6); 66(12.66) Principal Issues: 1. whether transferable flow-through warrants qualify as FTS Position: 1.if all conditions of definition in 66(15) met at the time warrant is exercised Reasons: 1. based on proposed transactions "agreement in writing" and other required conditions will be met when warrant is exercised XXXXXXXXXX 2009-033626 XXXXXXXXXX, 2009 Dear. ... The common shares of the Corporation are listed on the XXXXXXXXXX under the ticker symbol "XXXXXXXXXX " and are widely held by the public. 4. ... In particular, nothing in this letter should be interpreted as confirming, either expressly or implicitly: (i) whether the Corporation is a principal-business corporation; (ii) whether any particular expense incurred or to be incurred by the Corporation will qualify as CEE; (iii) whether any particular expense incurred or to be incurred by the Corporation will constitute a prescribed Canadian exploration and development overhead expense; (iv) the determination of whether the Warrant Shares will constitute prescribed shares; (v) the reasonableness of the allocation of the $ XXXXXXXXXX subscription price payable for a Series B Unit as described in paragraph 5(iii); and (vi) the computation of the adjusted cost base of the Series B Warrant to the Holder and the computation of the cost of the Warrant Share to the Holder and, in particular, the interaction of subsections 49(3) and 66.3(3). ...

2007 Ruling 2006-0215921R3 F- Don à une municipalité / 149(1)l) Unedited CRA Tags 248(31) 248(32) 149(1)l) Principales Questions: (1) Quel est le montant admissible d'un don fait à une municipalité lorsque la municipalité entend verser un montant équivalent à un organisme sans but lucratif (OSBL) à la suite du don? ... Entité C XXXXXXXXXX Entité D XXXXXXXXXX Entité E XXXXXXXXXX Entité F DÉFINITION DES TERMES Don Le don à être effectué par Société A à Entité B d'un montant de XXXXXXXXXX $. ... Montant du Don XXXXXXXXXX $. Période La durée de l'Emphytéose qui sera, au minimum, de XXXXXXXXXX ans. ...

2005 Ruling 2004-0096171R3- Treaty Benefits & Carrying Business in Canada Unedited CRA Tags 2(3) Principal Issues: 1) Whether the US corporation will be entitled to the benefits of the treaty notwithstanding the proposed transaction? ... For XXXXXXXXXX, approximately XXXXXXXXXX % of THE GROUP "Americas" revenue was from Canadian customers. ...

2007 Ruling 2007-0235881R3- Class of German Arrangement & Treaty Benefits Principal Issues: 1. ... In this letter, unless otherwise noted all statutory references are to the Income Tax Act (Canada), R.S.C. 1985, 5th Supplement, c. 1, as amended, (the "Act") each "technical" tax term used in this request has the same meaning as it has for purposes of the Act and each monetary reference is to CDN $. ... The Fund will be the only limited partner of the LP and will hold a XXXXXXXXXX% limited partnership interest and Newco will be the only general partner of the LP and will hold a XXXXXXXXXX % general partnership interest. 42. ...

2014 Ruling 2014-0532411R3- Convertible Notes & Part XIII Tax CRA Tags 212(3) 212(1)(b) 214(7) Principal Issues: In the event of a conversion of a convertible note for common shares, whether the excess (if any) determined under subsection 214(7) would constitute "participating debt interest" as defined in subsection 212(3)? ...

2000 Ruling 1999-0012763- Class 43-1 System & Heat Rate Requirements Unedited CRA Tags class 43-1 1104(14) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

2001 Ruling 2001-0109363- HEALTH & WELFARE TRUST Unedited CRA Tags 248(1) 6(1)(a)(i) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ...