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XXXXXXXXXX owns a XXXXXXXXXX % interest in XXXXXXXXXX. 3. The XXXXXXXXXX is owned and operated by XXXXXXXXXX under a joint venture agreement. 4. ... XXXXXXXXXX * XXXXXXXXXX XXXXXXXXXX 7. XXXXXXXXXX The cost of these houses to the employees is about $XXXXXXXXXX. ...

As of XXXXXXXXXX it had $XXXXXXXXXX of undeducted SR & ED expenditures and $XXXXXXXXXX of ITC to carry forward. ... Once ACO has used all of its ITC and SR & ED or at the time that revenue is generated from the new products resulting from the research, ACO will redeem its preferred shares and BCO will repay its loan to ACO. ...

Where a change of units does not result in a disposition, a T5008 Information Return is not required. 3) See 1) & 2) above XXXXXXXXXX 2000-004005 G. ... Document # 9905003(E) referenced in your letter of August 8 is a severed version of an advance income tax ruling to a specific mutual fund trust dealing with this issue. ...

XXXXXXXXXX 2000-004673 Danielle Bouffard À l'attention de XXXXXXXXXX Le 30 novembre 2000 Mesdames, Messieurs, Objet: Supplément de revenu garanti / Allocation au conjoint Lettre d'opinion 5-983124 du 5 juillet 1999 La présente est pour vous aviser que nous avons réexaminé le traitement fiscal du supplément de revenu garanti et de l'allocation au conjoint qui vous avait été décrit dans la lettre susmentionnée en titre. À moins d'indication contraire, tous les renvois législatifs ci-après sont des renvois aux dispositions de la Loi de l'impôt sur le revenu (" la Loi"). ...

ACo has approximately $XXXXXXXXXX of non-capital losses, $XXXXXXXXXX of unclaimed Scientific Research and Experimental Development (“SR & ED”) expenditures and $XXXXXXXXXX of unutilized Investment Tax Credit (“ITC”). ... Purpose of the Proposed Transactions Although both ACo and BCo are profitable, the purpose of the proposed transactions is to reduce taxes payable on a consolidated basis through the utilization of losses, the deduction of unclaimed SR & ED expenditures and the utilization of ITC’s that are available to ACo over a shorter period of time than would otherwise be achieved by virtue of the interest income. ...

These expenses are estimated to be as follows: Artists' Fees $ XXXXXXXXXX Artists' Marketing Fees XXXXXXXXXX Production costs XXXXXXXXXX Administrative, Marketing and Promotion XXXXXXXXXX Total expenses $ XXXXXXXXXX 11. ... The cash distributions to the Partners will be made on the following basis: a) For fiscal periods ending before XXXXXXXXXX % thereof to the General Partner and XXXXXXXXXX% thereof to the limited partners allocated equally among them on a unit pro rata basis. b) Thereafter, available cash will be distributed as XXXXXXXXXX% thereof to the General Partner and XXXXXXXXXX% thereof to the limited partners allocated equally among them on a unit pro rata basis. 19. ...

Newco's authorized share capital will consist of two classes of shares, as follows: (a) Common shares – voting, participating; and (b) Preferred Shares – non-voting, non-participating, redeemable/retractable at $XXXXXXXXXX/share, and subject to a price adjustment clause. 18. ...

The "Partnership" means XXXXXXXXXX, a partnership established under the laws of XXXXXXXXXX Targetsub is a XXXXXXXXXX % partner, and Target is a XXXXXXXXXX % partner. ...

The partners' equity (deficit) in the Partnership as of XXXXXXXXXX is as follows: Numberco (60% partnership interest) $ XXXXXXXXXX XXXXXXXXXX (40% partnership interest) XXXXXXXXXX $ XXXXXXXXXX The Partnership's income for 1997 is expected to be approximately $XXXXXXXXXX and there will be a write-down of the Partnership's assets for accounting purposes for approximately $XXXXXXXXXX. ...

XXXXXXXXXX 2014-056322 XXXXXXXXXX, 2015 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX Further to your request for an amendment to our Advance Income Tax Ruling dated XXXXXXXXXX 2014, our file number 2014-0539791R3 (the "Ruling"), issued to the above named taxpayer, the Ruling is amended by: (1) Adding the following paragraph in the Definition section of the Ruling after paragraph (h): "(h.1) "Hedge Fund" means XXXXXXXXXX, a fund resident in XXXXXXXXXX;". (2) Amending the definition of "Non-Resident Holders" in paragraph (l) by replacing the words "and certain of its subsidiaries" with the words ", certain subsidiaries of the Bank, and the Hedge Fund;". (3) Amending the definition of "Settlement Agreement" in paragraph (t) by replacing the words "the Non-Resident Noteholders" with the words "the Bank and certain of its subsidiaries". (4) Amending paragraph 11 by replacing the words "the Non-Resident Noteholders" with the words "the Bank and certain of its subsidiaries". (5) Amending paragraph 15 by: (a) Replacing the words "The Non-Resident Noteholders" in the second sentence with the words "The Bank and certain of its subsidiaries"; (b) Adding the sentence "The Hedge Fund held XXXXXXXXXX% of the Notes outstanding. ...