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Campbell   (613) 957-2067 November 29, 1989 Dear Mr. 19(1) Re:  Visit by officials from National Tax Administration December 5, 1989 Further to our meeting of Friday, November 24 and our conversation on Monday, November 27, we attach a copy of the agenda for the visit by 19(1). ...

23 January 1990 Ruling 90M01133 F- Liquidation of Corporation Unedited CRA Tags n/a 19(1) (613) 957-2070   C. ...

Campbell   (613) 957-2067 September 21, 1989 19(1) On April 13, 1989, we wrote to the Deputy Minister of Financing asking for information on the above noted.  ...

2004 Ruling 2003-0043361R3- SAR replacement with an agreement to issue shares Unedited CRA Tags 7 248(1)"S " Principal Issues: 1. ... However, under no circumstances will the share repurchase / redemption price exceed the amount as calculated in 8(b) and 8(d) above as determined at time of sale. 9. ... Multiplier: equals number of shares/ Remaining Value equals XXXXXXXXXX /$XXXXXXXXXX = XXXXXXXXXX iii. ...

At present, the shareholders of Canco and Canco's outstanding shares are as follows: Shareholder Class of Shares Number of Shares Stated Capital US Parent Common XXXXXXXXXX $ XXXXXXXXXX XXXXXXXXXX Common XXXXXXXXXX XXXXXXXXXX Total Common XXXXXXXXXX $ XXXXXXXXXX NRO One Class A XXXXXXXXXX $XXXXXXXXXX US Parent Class A XXXXXXXXXX XXXXXXXXXX Total Class A XXXXXXXXXX $XXXXXXXXXX NRO Two Class B XXXXXXXXXX $ XXXXXXXXXX Total Class B XXXXXXXXXX $ XXXXXXXXXX In connection with the Canco shareholders noted above, XXXXXXXXXX is a corporation formed under the laws of XXXXXXXXXX. ... On XXXXXXXXXX: (i) US Parent will contribute XXXXXXXXXX % of the common and Class A shares of NRO One and NRO Two to US Sub in exchange for common shares issued by US Sub; and (ii) US Parent and US Sub will then contribute their shares of NRO One and NRO Two to Partnership as a capital contribution. ...

The two new proposed transactions consist of (1) Child4 will settle a self benefit trust (XXXXXXXXXX) with a $ XXXXXXXXXX dollar bill and the XXXXXXXXXX class A common shares of the capital stock of Holdco1 that he owns, and, (2) XXXXXXXXXX will distribute, by way of a capital distribution, the Amalco C Notes to Child4. ... Insert immediately after the heading "PROPOSED TRANSACTIONS" the following new paragraph 42.1: Trust will be created by Child4 by transferring to Trust a $ XXXXXXXXXX dollar bill and the XXXXXXXXXX class A common shares of the capital stock of Holdco1 he owns. ...

Other Information As confirmed in our telephone conversation (XXXXXXXXXX / XXXXXXXXXX) of January 5, 1996, to the best of the knowledge of the XXXXXXXXXX none of the issues involved in the ruling request is being considered by a tax services or tax centre in connection with an income tax return already filed, and none of the issues involved is subject to a Notice of Objection. ... Yours truly, for Director Financial Industries Division Income Tax Rulings & Interpretations Directorate ...

XXXXXXXXXX 2.XXXXXXXXXX is a "public corporation" and a "taxable Canadian corporation within the meaning of those terms in subsection 89(1) of then Act. 3.XXXXXXXXXX a wholly owned subsidiary of XXXXXXXXXX The preference shares are voting, entitled to cumulative dividends and are redeemable at the option of the corporation. 4.XXXXXXXXXX was incorporated on XXXXXXXXXX and is governed by the XXXXXXXXXX 5.At XXXXXXXXXX had accumulated "non capital losses", within the meaning of that term in subsection 111(8) of the Act, of $ XXXXXXXXXX PROPOSED TRANSACTIONS 6.XXXXXXXXXX will borrow $XXXXXXXXXX from XXXXXXXXXX. ... Yours truly, for Director Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch ...

18 August 1993 Ruling 9321803 F- Capital Gains- Non-resident Entering Canada Unedited CRA Tags 110.6(5), 110.6(13), 110.6(3)   XXXXXXXXXX Dear XXXXXXXXXX RE:  XXXXXXXXXX XXXXXXXXXX Advance Income Tax Ruling This is in reply to your letter of July 12, 1993 requesting an advance income tax ruling on behalf of the above two named individuals with respect to the disposition of their rental property at XXXXXXXXXX As discussed with you over the telephone on August 6, 1993 we are unable to provide the ruling requested as it contains tax-related calculations and the transaction, though contemplated, is indefinite. ... Using the capital gain of $152,000 and the dates from your example (property purchased in September 1988 and sold in August 1993), the formula to produce the eligible real property gain would be: $152,000 x 42/60 = $106,400 Our use of your capital gain amount and similar dates does not imply acceptance of your calculations. ...

XXXXXXXXXX 2001-009267 XXXXXXXXXX, 2001 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX XXXXXXXXXX- Ruling # 2001-006970 This is in reply to your facsimile dated XXXXXXXXXX wherein you advised us of changes to the transactions described in our advance income tax ruling letter dated XXXXXXXXXX, 2001, our file number 2001-006970 (the "Ruling"). ... The following additional fact should have been described in the Ruling as taking place between the fact described in paragraph 6 and the fact described in paragraph 7: The terms of the preference shares are as follows:- Non-voting- Redeemable at $XXXXXXXXXX per share- XXXXXXXXXX % cumulative dividend payable XXXXXXXXXX Dividends have been fully paid on the preference shares up to and including XXXXXXXXXX. ...