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LP1 and LP2 directly hold a total of approximately XXXXXXXXXX % of the common shares of OpCo. 14. ... The interest rate charged on the NewCo Demand Note was XXXXXXXXXX % per annum. 28. ... The interest rate to be charged on the US$ NewCo III Demand Note will not exceed XXXXXXXXXX % per annum. 50. ...

Further, the class A shares will have a fixed, preferential, non-cumulative monthly dividend of XXXXXXXXXX % of the Redemption Amount. ... Further, the class B shares will have a fixed, preferential non-cumulative monthly dividend of XXXXXXXXXX % of the Redemption Amount. ... The class XXXXXXXXXX shares will have a fixed, preferential non-cumulative monthly dividend of XXXXXXXXXX % of the Redemption Amount. ...

The principal features are that the principal is repayable in US dollars and the outstanding principal bears interest at XXXXXXXXXX % per annum. 6. ... The principal features are that (i) the obligations are not secured, (ii) the principal is repayable in US dollars, (iii) for those issued on XXXXXXXXXX, the outstanding principal bears interest at XXXXXXXXXX % per annum, and (iv) for those issued on or after XXXXXXXXXX, the outstanding principal does not bear interest. ...

C. 1985(5th Supp.) c.1, as amended to the date hereof; (b) "A Co" means XXXXXXXXXX and is further described in paragraphs 1 to 3; (c) "CRA" means the Canada Revenue Agency; (d) "Final Index Value" means the value of the Index on the third business day prior to the Maturity Date of the Note; (e) "Index" means the XXXXXXXXXX; (f) "Index Return" means the positive amount, if any, that would be added to the Principal Amount and is calculated based on the change in the value of the Index between the Initial Index Value and Final Index Value as described in paragraph 8(b); (g) "Issue Date" means the date a Depositor advances an amount to A Co and the Notes are issued; (h) "Initial Index Value " means the value of the Index on the Issue Date of the Note; (i) "Maturity Date" means a date that is a stipulated date between XXXXXXXXXX and XXXXXXXXXX years after the Issue Date, upon which date the note would mature; (j) " Notes" means the Notes to be issued pursuant to the XXXXXXXXXX program and further described in paragraphs 6 and 7; (k) "OSFI" means the Office of the Superintendent of Financial Institutions; (l) "Regulations" means the Income Tax Regulations; and (m) "XXXXXXXXXX" means a fund-raising program which involves the issuance of debt obligations XXXXXXXXXX residents pursuant to a shelf prospectus, prospectus supplement and various terms supplements filed with XXXXXXXXXX; Statement of Facts 1. ...

Reasons: As with ruling 2006-019188 & officer analysis 2006-019338, the level of integration of the Fund's investing activities in the limited partnership, albeit indirectly, is sufficiently high for considering that the issuance of a guarantee is not an undertaking by itself. ... XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Our understanding of the facts and proposed transactions is as follows: Definitions In this letter, the following terms have the meaning specified: (a) “Act” means the Income Tax Act, R.S.C. 1985 (5th Suppl.) c.1, as amended to the date hereof; (b) “ARM” means an adjustable rate mortgage (with a floating interest rate), as described in 13 below; (c) XXXXXXXXXX; (d) “capital gain” has the meaning assigned by subsection 248(1) of the Act; (e) “capital loss” has the meaning assigned by subsection 248(1); (f) “capital property” has the meaning assigned by subsection 248(1); (g) XXXXXXXXXX (h) “CRA” means the Canada Revenue Agency; (i) “excluded obligation” has the meaning assigned by paragraph 214(8)(a) of the Act; (j) “excluded property” has the meaning assigned by paragraph 116(6)(d) of the Act; (k) “Floating Rate XXXXXXXXXX ” means XXXXXXXXXX issued in respect of a pool of VRM (see ‘u’ below), ARM, or a WAC XXXXXXXXXX (see ‘v’ below); (l) “Investors” has the meaning assigned in 7 below; (m) “Issuer” has the meaning assigned in 7 below; (n) “investment contract” has the meaning assigned by subsection 12(11) of the Act; (o) “mark-to-market property” has the meaning assigned by subsection 142.2(1) of the Act; (p) “XXXXXXXXXX; (q) “prescribed debt obligation” has the meaning assigned by subsection 7000(1) of the Income Tax Regulations; (r) “Private Insurer” has the meaning assigned in 4 below; (s) “Proposed Transactions” means the transactions described in 7 to 28 below; (t) “specified debt obligation” has the meaning assigned by subsection 142.2(1); (u) “VRM” means a variable rate mortgage (with a floating interest rate), as described in 13 below; (v) “WAC XXXXXXXXXX ” means XXXXXXXXXX bearing an interest rate based on the weighted average coupon of mortgages (VRM or ARM) comprising the pool, as described in 15 below. ...

DEFINITIONS (a) "adjusted cost base has the meaning assigned by section 54; (b) "Canco" means XXXXXXXXXX, an unlimited liability company incorporated under the laws of the Province of XXXXXXXXXX; (c) "Canco Note 1" means the promissory note evidencing indebtedness owing by Canco on XXXXXXXXXX in the principal amount of US$XXXXXXXXXX bearing interest annually at a rate of XXXXXXXXXX %; (d) "Canco Note 2" means the promissory note evidencing indebtedness owing by Canco on XXXXXXXXXX in the principal amount of US$XXXXXXXXXX bearing interest annually at a rate of XXXXXXXXXX %; (e) "Canco Notes" means Canco Note 1 and Canco Note 2; (f) "Code" means the Internal Revenue Code of 1986, 26 U.S.C.; (g) "Convention" means the Convention Between the United States of America and Canada With Respect to Taxes on Income and on Capital Signed on 26 September 1980, as Amended by the Protocols Signed on 14 June 1983, 28 March 1984, 17 March 1995, 29 July 1997 and 21 September 2007; (h) "GP means XXXXXXXXXX, a XXXXXXXXXX corporation; (i) "LP1" means XXXXXXXXXX, a XXXXXXXXXX limited partnership; (j) "LP2" means XXXXXXXXXX, a XXXXXXXXXX limited partnership; (k) "Paragraph" means a numbered paragraph in this letter; (l) "taxable Canadian corporation" has the meaning assigned by subsection 89(1); (m) "taxable income" has the meaning assigned by subsection 248(1); (n) "taxable year" has the meaning assigned under the Code; and (o) "United States" means the United States of America. ...

Our understanding of the facts and proposed transactions is as follows: In this letter, the following terms have the meaning specified: (a) "Act" means the Income Tax Act, R.S.C. 1985 (5th Suppl.) c.1, as amended to the date hereof; (b) "ARM" means an adjustable rate mortgage (with a floating interest rate), as described in 13 below; (c) "Canco" means XXXXXXXXXX; (d) "capital gain" has the meaning assigned by subsection 248(1); (e) "capital loss" has the meaning assigned by subsection 248(1); (f) "capital property" has the meaning assigned by subsection 248(1); (g) XXXXXXXXXX; (h) "CRA" means the Canada Revenue Agency; (i) "excluded obligation" has the meaning assigned by paragraph 214(8)(a) of the Act; (j) "excluded property" has the meaning assigned by paragraph 116(6)(d) of the Act; (k) "Floating Rate XXXXXXXXXX " means XXXXXXXXXX issued in respect of a pool of VRM (see 'u' below), ARM, or a WAC XXXXXXXXXX (see 'v' below); (l) "Investors" has the meaning assigned in 7 below; (m) "Issuer" has the meaning assigned in 7 below; (n) "investment contract" has the meaning assigned by subsection 12(11); (o) "mark-to-market property" has the meaning assigned by subsection 142.2(1); (p) XXXXXXXXXX; (q) "prescribed debt obligation" has the meaning assigned by subsection 7000(1) of the Income Tax Regulations; (r) "Private Insurer" has the meaning assigned in 4 below; (s) "Proposed Transactions" means the transactions described in 7 to 28 below; (t) "specified debt obligation" has the meaning assigned by subsection 142.2(1); (u) "VRM" means a variable rate mortgage (with a floating interest rate), as described in 13 below; (v) "WAC XXXXXXXXXX " means XXXXXXXXXX bearing an interest rate based on the weighted average coupon of mortgages (VRM or ARM) comprising the pool, as described in 15 below. ...

Pursuant to certain option agreements entered into in XXXXXXXXXX and XXXXXXXXXX, Pubco is in the process of earning a XXXXXXXXXX % interest in certain mining claims in the Properties. 8. ... On XXXXXXXXXX, the following transactions occurred: (a) Subco 2 issued to Pubco XXXXXXXXXX common shares and XXXXXXXXXX warrants to purchase common shares in Subco 2 in exchange for XXXXXXXXXX new treasury shares and XXXXXXXXXX share purchase warrants of Pubco; and (c) Subco 2 agreed to acquire a XXXXXXXXXX % interest in certain XXXXXXXXXX and, in exchange, to provide consideration that includes the issuance of XXXXXXXXXX common shares, $XXXXXXXXXX, XXXXXXXXXX Pubco common shares and a total of $XXXXXXXXXX of exploration expenditures. 15. ...

NR Holdco will lend the funds to BBCo pursuant to a legal document to pay interest thereon at a rate XXXXXXXXXX % below NR Holdco's cost to borrow. 15. ... BBCo will loan the funds, swept from the Participants and borrowed from NR Holdco, to the Participants pursuant to a legal document to pay interest thereon at the rate paid by BBCo to NR Holdco plus XXXXXXXXXX %. ...