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XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

SUBJECT: Reorganization under 132.2 XXXXXXXXXX XXXXXXXXXX, 2005 Dear Messrs: Re: Advance Income Tax Ruling XXXXXXXXXX (XXXXXXXXXX Tax Services Office, XXXXXXXXXX Taxation Centre) XXXXXXXXXX (XXXXXXXXXX Tax Services Office) This is in reply to your emails dated XXXXXXXXXX in which you requested amendments to the facts and proposed transactions set out in the Advance Income Tax Ruling letter (document # 2005-011989) issued to the above-referenced taxpayers on XXXXXXXXXX, 2005 (the Ruling). ...

XXXXXXXXXX & Act refers to disposition of "part thereof" 2. ...

19 March 1993 Ruling 9307673 F- Commutation of Annuity Contracts Unedited CRA Tags 56(1)(d)   XXXXXXXXXX  Attention:  XXXXXXXXXX Dear Sirs: RE:  Structured Settlements This is in reply to your recent letter received in this office on March 17, 1993 concerning the commutation of annuity contracts purchased by an insurer to fund its liability under a "structured settlement" as contemplated in Interpretation Bulletin IT-365R2. ...

5 May 1993 Ruling 9308451 F- Hong Kong War Memorial Pension Unedited CRA Tags 81(1)(e)   ISSUE SHEET Issue We have been contacted by the Victoria District Office to determine whether or not an individual in receipt of a pension from the Hong Kong War Memorial Pension is taxable in Canada. ...

The holders of the Common Shares will be entitled to one vote per share and the Class A Special Shares will each have a fraction of a vote determined by a formula that ensures the total number of votes attributable to the Class A Special Shares equals XXXXXXXXXX % of the total number of votes attributable to all of the issued and outstanding voting shares of the Transferee. ...

Paragraph 3. is amended to read: "Trust One holds a XXXXXXXXXX % interest in the Limited Partnership. ...

Yours truly, XXXXXXXXXX Manager for Director International & Trusts Division Income Tax Rulings Directorate ...

Employer / employee relationship established. XXXXXXXXXX 2001-009179 XXXXXXXXXX, 2001 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX (the "Employer") XXXXXXXXXX (the "Employee") This is in reply to your letter of XXXXXXXXXX, requesting an advance income tax ruling on behalf of the above-referenced taxpayers. ...

The ruling is given subject to the general limitations and qualifications set out in Information Circular 70-6R4 issued by the Canada Customs & Revenue Agency on January 29, 2001, and is binding upon the Agency provided that the proposed transactions are completed on or before XXXXXXXXXX. ...