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All of its activities required to acquire, own and collect portfolios – as described more fully in paragraphs 14 through 19 below – are performed by employees of FA4. ... Therefore, all activities required to acquire, own and collect portfolios – as described more fully in paragraphs 14 through 19 below – are performed by employees of FA4. ... Furthermore, FA4 – directly and through LP – and the FA5 Subsidiaries each carry on the business of acquiring and collecting portfolios, and this would be a single business if they were carried on by a single affiliate. 25) The activities of LP are critical to the profitability of the FA5 New Portfolio. ...

XCo and YCo are each XXXXXXXXXX % owned and controlled by ZCo. 4. SisterlossCo and ProfitCo have been related and affiliated companies since XXXXXXXXXX. 5. ... At XXXXXXXXXX, SisterlossCo owed approximately $XXXXXXXXXX to ForCo, bearing interest at a rate of XXXXXXXXXX % per annum. ... As evidence of the indebtedness, ProfitCo will issue to SisterlossCo a demand promissory note with a principal amount equal to the amount of the SisterlossCo Loan and bearing interest at an appropriate arm's length rate expected to be in the range of approximately XXXXXXXXXX % to XXXXXXXXXX %. 15. ...

Holdco3 owns XXXXXXXXXX % of all the issued and outstanding common shares and XXXXXXXXXX preferred shares of Profitco. ... Class H preferred shares are non-voting, redeemable, entitled to a non-cumulative dividend of XXXXXXXXXX % per year and refundable in priority on Class A, B, C and D shares. 3. ... The allocation of the taxable income between XXXXXXXXXX and XXXXXXXXXX is XXXXXXXXXX % and XXXXXXXXXX %, respectively. ...

XXXXXXXXXX issued share capital consisted of: Number and class of shares Shareholder PUC XXXXXXXXXX Class B preferred Canco 1 $XXXXXXXXXX XXXXXXXXXX Class E preferred Canco 1 $ XXXXXXXXXX XXXXXXXXXX common shares Canco 1 $ XXXXXXXXXX XXXXXX Class D preferred Estate XXXXXXXX $ XXXXXXXXXX XXXXX Class E preferred shares Estate XXXXXXXX $ XXXXXXXXXX The Class B, D and E preferred shares were non-voting, non-cumulative, non-participating, redeemable at $XXXXXXXXXX per share, respectively. ... XXXXXXXXXX issued share capital consisted of: Number and class of shares Shareholder PUC XXXXXXXX Class C preferred XXXXXXXXX $XXXXXXXXXX XXXXXXXX common shares XXXXXXXXXX $ XXXXXXXXXX XXXXXXXX Class D preferred XXXXXXXXXX $XXXXXXXXXX XXXXXXXXXX Class B shares Canco 1 $XXXXXXXXXX The Class C and D preferred shares were non-participating, non-voting, redeemable and entitled to non-cumulative dividends of XXXXXXXXXX % per annum. ... Its issued share capital consists of: Number and class of shares Shareholder PUC XXXXXXXXXX Class B preferred Amalco II $XXXXXXXXXX XXXXXXXXXX common shares Amalco II $XXXXXXXXXX The Class B preferred share is redeemable, carries a dividend rate of XXXXXXXXXX %, and is non-cumulative, non-participating, and voting. ...

The XXXXXXXXXX Promissory Note evidences a debt obligation of O Co to B Co for the original principal amount of $XXXXXXXXXX together with interest thereon at the rate of XXXXXXXXXX % calculated and compounded, XXXXXXXXXX. ... The Trust Notes will mature on XXXXXXXXXX and will be repayable in equal semi-annual payments of principal and interest computed at a rate that is anticipated to be in the range of XXXXXXXXXX % to XXXXXXXXXX % per annum, calculated and compounded semi-annually, not in advance, depending on the exigencies of the market. ...

Groupe versera à XXXXXXXXXX un montant forfaitaire équivalant à XXXXXXXXXX % des coûts relatifs au Projet, ce qui devrait représenter un montant de l'ordre de XXXXXXXXXX $. ... Pour les fins de la réalisation des Travaux correcteurs conçus et réalisés par Groupe, XXXXXXXXXX versera à Groupe, à la date de signature de l'Entente, la somme de XXXXXXXXXX $ et mettra à la disposition de Groupe un montant additionnel de XXXXXXXXXX $ à titre de fonds de travaux correcteurs dans les XXXXXXXXXX jours de la date de l'émission du certificat d'autorisation, délivré en regard du Projet, conformément à la section IV.1 de la Loi sur la qualité de l'environnement. 18. ...

Principal Issues: Certificate of Deposit to be issued to non-residents with an interest return based on increase in S&P 500 index over the term of the deposit to a maximum of XXXXXXXXXX %. ... A is entitled to be repaid the Principal Amount of the CD and to receive, in addition, an amount of interest (the "Return") calculated on the basis of the application of a formula, linked to the Standard & Poor's 500 Index (the "Index"), to the Principal Amount of the CD: Principal Amount x Final Index Level- Initial Index Level Initial Index Level to a maximum of: Principal Amount x XXXXXXXXXX% where: Final Index Level = the Index level at the maturity date; and Initial Index Level = the Index level on the issue date of the CD. 9. ...

Of the issued and outstanding Holdco Shares, Parentco owns approximately XXXXXXXXXX % of the XXXXXXXXXX Shares and approximately XXXXXXXXXX % of the XXXXXXXXXX Shares. In addition, XXXXXXXXXX directly hold, in the aggregate, less than XXXXXXXXXX % of the XXXXXXXXXX Shares and less than XXXXXXXXXX % of the XXXXXXXXXX Shares. ... Of the issued and outstanding Subco Shares, Holdco owns approximately XXXXXXXXXX % of the XXXXXXXXXX shares and approximately XXXXXXXXXX % of the XXXXXXXXXX shares. ...

.), as amended to the date hereof; (d) "active business" has the meaning assigned by subsection 95(1) of the Act; (e) "arm's length" has the meaning assigned by section 251 of the Act; (f) "B Co" means XXXXXXXXXX as described in Paragraph 9; (g) "B Co Shares" means shares of B Co as described in Paragraph 12; (h) "C Co Shares" means shares of XXXXXXXXXX as described in Paragraph 12; (i) "CBCA" means the Canada Business Corporations Act; (j) "CRA" means the Canada Revenue Agency; (k) "C Co" means XXXXXXXXXX as described in Paragraph 7; (l) "D Co" means XXXXXXXXXX as described in Paragraph 10; (m) "D Co Shares" means the shares of D Co as described in Paragraph 12; (n) "E Co" means XXXXXXXXXX as described in Paragraph 9; (o) "E Co Leasing" means a subsidiary of a XXXXXXXXXX holding company directly held by E Co as described in Paragraph 9; (p) "fair market value" means the amount at which property would exchange hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of the relevant facts; (q) "H Co " means XXXXXXXXXX as described in Paragraph 10; (r) "I Co" means XXXXXXXXXX as described in Paragraph 9; (s) "IF Co" means XXXXXXXXXX. as described in Paragraph 8; (t) "LP" means XXXXXXXXXX and Company LP as described in Paragraph 8; (u) "New LP" means a new limited partnership as described in Paragraph 20; (v) "Note" means a promissory note issued by A Co to W Co as described in Paragraph 15; (w) "paid-up capital" has the meaning assigned by subsection 89(1) of the Act; (x) "Paragraph" means a numbered paragraph in this advance income tax ruling; (y) "Preference Shares" means voting preference shares of A Co as described in Paragraph 6; (z) "principal amount" has the meaning assigned by subsection 248(1) of the Act; (aa) "Proposed Transactions" means the proposed transactions described in Paragraphs 22 to 29; (bb) "Regulations" means Income Tax Regulations, Consolidated Regulations of Canada, Chapter 945 as amended to the date hereof; (cc) "Reinvestment Agreement" means an agreement between T Co, A Co and W Co as described in Paragraph 18; (dd) "related persons" has the meaning assigned by subsection 251(2) of the Act; (ee) "Share Transfer Agreement" means a share transfer agreement entered into by A Co and W Co as described in Paragraph 12; (ff) "taxable Canadian corporation" has the meaning assigned by subsection 89(1) of the Act; (gg) "T Co" means XXXXXXXXXX as described in Paragraph 11; (hh) "third parties" means persons who act at arm's length with the X Group; (ii) "Transferred Shares" has the meaning described in Paragraph 12; (jj) "Treaty" means the Canada-United States Income Tax Convention; (kk) "W Co" means XXXXXXXXXX as described in Paragraph 2; (ll) "X Co" means XXXXXXXXXX as described in Paragraph 1; (mm) "X Group" means X Co and entities related to X Co; (nn) "Z Co" means XXXXXXXXXX, as described in Paragraph 6. ... On XXXXXXXXXX, A Co and W Co entered into a share transfer agreement (the "Share Transfer Agreement") pursuant to which A Co agreed to acquire from W Co, and W Co agreed to transfer to A Co, XXXXXXXXXX% of the shares of C Co (the "C Co Shares"), XXXXXXXXXX % of the shares of B Co (the "B Co Shares"), and XXXXXXXXXX% of the shares of D Co (the "D Co Shares") (collectively, the "Transferred Shares"). ... A Co, as limited partner, and IF Co, as general partner, formed a limited partnership in XXXXXXXXXX, New LP, under " XXXXXXXXXX " on XXXXXXXXXX. 21. ...

XXXXXXXXXX 2004-006815 XXXXXXXXXX, 2004 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX (the "Corporation") (Account # XXXXXXXXXX) XXXXXXXXXX. (the "Employer") (Account # XXXXXXXXXX) This is in reply to your letter of XXXXXXXXXX, in which you requested an advance income tax ruling on behalf of the Corporation, the Employer and the Participants. ... The commission rates range from XXXXXXXXXX % to XXXXXXXXXX % of the XXXXXXXXXX gross production, with the commission rates increasing as the XXXXXXXXXX level of gross production increases as set out in the following table. ...