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XXXXXXXXXX 2005-014474 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX XXXXXXXXXX This is in reply to your facsimile dated XXXXXXXXXX in which you requested amendments to the facts and proposed transactions set out in the Advance Income Tax Ruling letter (document # 2005-011909) issued to the above-referenced taxpayers on XXXXXXXXXX, 2005 (the "Ruling"). ...

Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

XXXXXXXXXX 2005-011790 XXXXXXXXXX, 2005 Dear Messrs: Re: Advance Income Tax Ruling XXXXXXXXXX (XXXXXXXXXX Tax Services Office, XXXXXXXXXX Taxation Centre) XXXXXXXXXX (XXXXXXXXXX Tax Services Office, XXXXXXXXXX Taxation Centre) This is in reply to our conversation dated XXXXXXXXXX in which you requested amendments to the rulings set out in the Advance Income Tax Ruling letter (document # 2005-011790) issued to the above-referenced taxpayers on XXXXXXXXXX 2005 (the Ruling). ...

Position: No Reasons: prior wording of reg. 5000(7) parallels wording in 108(2)(b); Finance saw fit to amend the definition of pooled fund trust because they were of the opinion that "special warrants" & other such convertibles did not fit the category of marketable securities; therefore no ruling given; discussions with Finance indicate amendment to 108(2)(b) is coming that will mirror the changes made to ss. 5000(7) of the Regulations; therefore decline to rule amendment to Act required. 964172 XXXXXXXXXX L. ...

Reasons FOR POSITION:position on 110(1)(d) & 7(3)(b) under review. payment taxable when election made. ...

28 May 1993 Ruling 9313173 F- Retiring Allowance Re-employment Unedited CRA Tags 56(1)(a(ii), 248(1) Retiring allowance   XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Advance Ruling Request XXXXXXXXXX This is in reply to your letter of May 5, 1993 requesting an advance income tax ruling concerning amounts paid to certain individuals by the XXXXXXXXXX on termination of their employment. ...

22 April 1993 Ruling 9311411 F- Stripped Bonds Unedited CRA Tags 12(4), 12(9), ITR 7000, 20(14)   QUESTION See attached letter from XXXXXXXXXX to XXXXXXXXXX, dated April 8, 1993, concerning the proper taxation of stipped bonds. ...

15 November 1993 Ruling 9231471 F- Prepaid Funeral Services Unedited CRA Tags 75(2), 20(1)(c), 104   XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Prepaid Funeral Services We are writing to advise you of the Department's current position concerning the taxation of interest received on funds held in trust to provide funeral services. ...

Yours truly, XXXXXXXXXX for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

As a result of the above change we confirm that subparagraphs 22(i) and (ii) of the Ruling are cancelled and replaced as follows: (i) the Family B Properties; (ii) a XXXXXXXXXX % beneficial undivided interest in the Co-Tenancy Properties and the XXXXXXXXXX Properties; Notwithstanding the above noted amendments to the proposed transactions, we confirm that, subject to the conditions set out therein, the rulings given in the Ruling will continue to be binding on the Canada Customs and Revenue Agency ("CCRA") in accordance with the practice outlined in Information Circular 70-6R3, dated December 30, 1996, provided that all the proposed transactions are completed in the manner otherwise described in the Ruling, as amended herein, before XXXXXXXXXX. ...