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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. ...

Reasons: Does not affect the ruling given in file # 992747. XXXXXXXXXX XXXXXXXXXX 2000-002737 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 2000 Dear Sirs: Re: XXXXXXXXXX- Advance Income Tax Ruling- Business Number XXXXXXXXXX This is in response to your letter of XXXXXXXXXX, requesting an extension of time for completing the proposed transactions in the advance income tax ruling (File # 992747) (the "Ruling") issued to your firm on behalf of the above-noted taxpayers on XXXXXXXXXX, 1999. ...

10 November 1989 Ruling 74133 F- Investment Tax Credit- Qualified Transportation Equipment Unedited CRA Tags 4601(c)(i)(E), 14   November 10, 1989 TORONTO DISTRICT OFFICE Head Office Audit Review Section Specialty Rulings Business Enquiries Group Roberta Albert 148-2-1 (613) 957-2098 G. ... According to the Canadian Almanac & Directory 1988 Clark Pitman Ltd 24(1) is, not an urban municipality and as a result licenses would be required under the TTA for any transportation service being run out of the community. ...

Generally, subsection 85(4) of the Act operates, among other things, (i)     to deny the capital loss that would otherwise be incurred by a taxpayer who transfers capital property to a corporation; and (ii)     to provide for an addition to the cost base to the taxpayer of the shares of the transferee corporation owned by the taxpayer immediately after the transfer. if the transferee corporation was, immediately after the transfer, controlled, directly or indirectly in any manner whatever, by the taxpayer, by the spouse of the taxpayer or by a person or group of persons by whom the taxpayer was controlled, directly or indirectly in any manner whatever. ...

The Promissory Notes will bear interest at XXXXXXXXXX %, a rate that is reasonable based on current market rates for BB+ rated industrial entities. 30. ... For XXXXXXXXXX, B Co allocated approximately XXXXXXXXXX % of its taxable income to XXXXXXXXXX. and XXXXXXXXXX % to XXXXXXXXXX. ...

NRsub 2 owns a XXXXXXXXXX % limited partnership interest in NRCo Partnership. 17. ... The XXXXXXXXXX % interest in Leaseco not owned by NRCo is owned, indirectly, by Mr. ... B also owns, indirectly, a XXXXXXXXXX % interest in Leaseco described in Paragraph 18 above. 21. ...

Le XXXXXXXXXX Groupe a empruntée la somme de XXXXXXXXXX $ de XXXXXXXXXX. ... Le XXXXXXXXXX, Acquis Co a acheté de Groupe des actifs ayant une juste valeur marchande de XXXXXXXXXX $ et un coût fiscal de XXXXXXXXXX $. ... (a)(i)B représentent un surplus de liquidités temporaires dont la juste valeur marchande s'élève à XXXXXXXXXX $. ...

" means XXXXXXXXXX, a wholly-owned subsidiary of the Fund, incorporated under the laws of the Province of XXXXXXXXXX; "Declaration of Trust" means the declaration of trust establishing and governing the Fund, dated XXXXXXXXXX, as amended and restated from time to time, including most recently on XXXXXXXXXX; "Fund" means, the XXXXXXXXXX, an open-ended mutual fund trust formed under the laws of the Province of XXXXXXXXXX pursuant to the Declaration of Trust; "Guaranteed Amounts" has the meaning assigned to it in paragraph 10 below; "Non-portfolio property" has the meaning assigned by subsection 122.1(1); "Qualified REIT property" has the meaning assigned by subsection 122.1(1); "Real estate investment trust" has the meaning assigned by subsection 122.1(1); "Real or immovable property" has the meaning assigned by subsection 122.1(1); and "Subsidiary" of the Fund means any entity, corporation, trust, or partnership in which the Fund holds, either directly or indirectly (through one or more Subsidiaries), XXXXXXXXXX % or more of the beneficial interest therein, including, without limitation, in respect of a corporation, XXXXXXXXXX % or more of the shares of each class of the corporation, in respect of a trust, XXXXXXXXXX % or more of the beneficial interest in the trust, and in respect of a partnership, XXXXXXXXXX % or more of the partnership units or interest in the partnership. ...

(2) Is withholding tax at XXXXXXXXXX % applicable on benefit? (3) Do the transactions constitute a series of loans and repayments? ... Note A bears interest at XXXXXXXXXX % per annum and matures in approximately XXXXXXXXXX years. ... Note B bears interest at XXXXXXXXXX % per annum and is repayable on demand. 4. ...

A XXXXXXXXXX is subject to income tax in Foreign Country #2 on its worldwide income at the same rate as other XXXXXXXXXX companies (XXXXXXXXXX %). However, a XXXXXXXXXX is entitled to a foreign currency earnings credit to a maximum of XXXXXXXXXX % of its XXXXXXXXXX income tax liability in respect of its XXXXXXXXXX. ... Yours truly, for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...