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The relevant facts regarding these corporations are summarized below: Name of Date of Fiscal Corporate Corporation Controlling shareholder(s) incorporation year end account # XXXXXXXXXX/Aco XXXXXXXXXX XXXXXXXXXX/Cco XXXXXXXXXX/Aco XXXXXXXXXX XXXXXXXXXX/Bco XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Mr. ... C XXXXXXXXXX ("XXXXXXXXXX/Fco") * Date of amalgamation All the corporations described herein file their corporate tax returns at the XXXXXXXXXX Taxation Centre and deal with the XXXXXXXXXX Tax Services Office regarding their tax affairs. 2. ...

(c) The activities of "XXXXXXXXXX " are specifically excluded from the "qualified activities" under the definition of the later term in section 5202 of the Regulations. ... The initial Distribution Percentage of the Partners at the Closing after the initial capital contributions made by D Co. and R Co. as referred to in 17 above will be as follows: Distribution Percentage (%) B Co. ...

On the date hereof XXXXXXXXXX/ACO owns XXXXXXXXXX % of XXXXXXXXXX issued and outstanding common shares. 20. ... At the time of the acquisition, XXXXXXXXXX owned XXXXXXXXXX % of the shares of XXXXXXXXXX. ...

DC1 will hold the XXXXXXXXXX % undivided interest in Property2, Property3, Property4 and the Subco shares, if any, received by it from DC2 as capital property. 16. Contemporaneously with the transfer of property described in paragraph 15 above, DC3 will transfer to DC1 at fair market value all of its properties, including its XXXXXXXXXX % undivided interest in each of Property1, Property2 and Property3. ...

The approximate FMV of the assets of DC on XXXXXXXXXX are as follows: Assets FMV ($) Cash XXXXX Cash surrender value of life insurance policy XXXXX Marketable Securities XXXXX Total XXXXX The approximate FMV of the liabilities of DC on XXXXXXXXXX are as follows: Liabilities FMV ($) Taxes payable XXXXX Shareholder Loan XXXXX Total XXXXX PROPOSED TRANSACTIONS The Proposed Transactions will occur in the order presented unless otherwise indicated, with the exception of filing the applicable election forms, which will be filed within the applicable due dates, unless otherwise indicated, following the completion of the Proposed Transactions. ...

. / Canco6, representing XXXXXXXXXX% of the issued and outstanding share capital of the company; iii. XXXXXXXXXX Class A voting preferred shares of XXXXXXXXXX / Canco3 with a redemption value of $XXXXXXXXXX per share or $XXXXXXXXXX in aggregate; iv. ...

2002 Ruling 2002-0140733- XXXXXXXXXX- Sequential Butterfly Unedited CRA Tags 55(3)(b) 88(1) & (2) 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. ... The holders of the BF Subco Class A Special Shares shall be entitled to receive, as and when declared from time to time by the board of directors, dividends not exceeding an amount equal to XXXXXXXXXX % per annum calculated on the aggregate BF Subco Class A Redemption Amount. ... As a result, ChildA1 will own shares carrying more than XXXXXXXXXX % of the total votes attaching to all outstanding shares of ChildA1Co. ...

Principal Issues: (i) Can we rule that a particular royalty, relating to XXXXXXXXXX in Canada, will constitute a "XXXXXXXXXX "? ... As outlined in more detail in Ruling 2, Y Co. acquired its working interest in the Project on XXXXXXXXXX pursuant to an arrangement whereby A Co. sold to Y Co. its XXXXXXXXXX% undivided working interest in the Project ("Working Interest 2") reserving a XXXXXXXXXX % net profit interest (the royalty so reserved being "Royalty 2"). ... The Purchase and Sale Agreement closed on XXXXXXXXXX with the base purchase price being adjusted and allocated as follows: New Trust Ordinary Units $ XXXXXXXXXX New Trust Series 1 Special Units XXXXXXXXXX New Trust Debt XXXXXXXXXX C Co. shares XXXXXXXXXX Option XXXXXXXXXX $XXXXXXXXXX Pursuant to the Purchase and Sale Agreement, there may be further adjustments to the purchase price in the XXXXXXXXXX day period following the closing of that agreement. 31. ...

Reasons: 1) See provisos in the ruling given. 2) See provisos in the ruling given. 3) It meets the required level of integration discussed in ITTN # 34. ...

The significant assets of DC include: (i) cash; (ii) investment assets in the form of three (3) XXXXXXXXXX properties (Property1, Property2 and Property3); and (iii) a XXXXXXXXXX per cent (XXXXXXXXXX %) equity interest (Common Shares) together with certain indebtedness in Opco which is a corporation engaged in the business of XXXXXXXXXX. ...