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. * As defined in draft section 143.2. The opinions expressed above are provided in accordance with paragraph 22 of Information Circular 70-6R2. ...

July 17, 1997 Calgary Tax Services Office Resource Industries Graham Hoard Section Acting Assistant Director Peter Lee Verification & Enforcement (613) 957-8977 Attention: Doug Reeh Large File Case Manager 7-970054 XXXXXXXXXX Terminal Loss and Resource Allowance This is in reply to your memorandum of January 2, 1997 wherein you requested our opinion on whether a terminal loss of $XXXXXXXXXX resulting from the disposition of its mining assets by the corporation formed in an amalgamation of XXXXXXXXXX, should be disallowed in computing the amalgamated corporation's income under the Income Tax Act (the "Act"). ...

The terms of the Holdco I Note will provide that a portion of the interest payable on the note (approximately XXXXXXXXXX %) will be paid in the taxation year the expense is incurred and the unpaid portion will be paid prior to the end of the second taxation year following the taxation year in which the expense was incurred. 19. ...

XXXXXXXXXX will realize a foreign exchange loss of approximately $XXXXXXXXXX on the assumption of Loan 1, as a result of the fluctuation in the exchange rate of US $ on the day of the assumption compared to the rate when the loan was made. 28. ...

XXXXXXXXXX will sell, at fair market value, to Subco XXXXXXXXXX % of its cash and near-cash property and investment property. ...

The Exercise Price will be approximately XXXXXXXXXX % of the market price (on the XXXXXXXXXX Stock Exchange) of the CCo Stock (XXXXXXXXXX) on the date on which the offering of the Units is priced. ...

April 24, 1998 Policy & Procedures Marie-Marthe Gagnon International Audit Division (613) 957-8953 International Tax Directorate Attention: René Fleming, Interim Manager 7-973015 Section 122.3- Overseas Employment Tax Credit This is in reply to your letter of November 12, 1997, requesting our comments concerning the application of the Overseas Employment Tax Credit in a particular factual situation. ...

On the incorporation of XXXXXXXXXX, 1 common share will be issued to XXXXXXXXXX for aggregate consideration of $ XXXXXXXXXX. 20. ...

Position TAKEN: 1) No 2) No 3) Yes 4) No Reasons FOR POSITION TAKEN: 1) Consistent with the position in IT-385R2 and in previous rulings (973094, 972779 & 970604) 2) The variation is not significant enough to consider that there has been a disposition (972779). 3) The Distribution pursuant to subsection 107(2) is consistent with Finance's comments contained in the Technical Notes regarding the 21-year rule. 4) This issue was referred to the GAAR Committee and it was recommended that GAAR not apply to the proposed transactions. ...

Subsection 227(8) of the Act states “... every person who in a calendar year has failed to deduct or withhold any amount as required by subsection 153(1) or section 215 is liable to a penalty of (a) 10% of the amount that should have been deducted or withheld; or (b) where at the time of the failure a penalty under this subsection was payable by the person in respect of an amount that should have been deducted or withheld during the year and the failure was made knowingly or under circumstances amounting to gross negligence, 20% of that amount. 6. ...