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

Principal Issues: Whether proposed foundation for R & D in XXXXXXXXXX qualifies under 149(1)(j) Position: Limited ruling provided that it will be considered the be constituted exclusively for the purpose of carrying on or promoting SR&ED for the purposes of 149(1)(j). ...

Principal Issues: 1)whether 254(a) applies to the purchase by an RCA trust of annuities providing periodic payments for life & a lump sum for guaranteed portion for the spouse of a deceased employee; 2)whether the employer may loan (i.e. it won't be considered a contribution) the amount needed by the RCA trust to make up the difference between the RCA assets and the price of the annuities (loan to be repaid by the amount of refundable tax the refund of which is triggered by the purchase of the annuities); 3)whether the annuities will be considered subject property of the RCA thereby preventing refund of Part XI.3 tax to custodian after final return filed. ...

Reasons: 1) & 2) Routine- see E9700303. XXXXXXXXXX 970029 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 1997 Re: Advance Income Tax Ruling XXXXXXXXXX Incentive Compensation Arrangement This is in reply to your letters of XXXXXXXXXX, in which you request an advance income tax ruling on behalf of the above-named taxpayer, and further to our telephone conversations XXXXXXXXXX. ...

Sale at FMV after acquisition would result in no gain. 2.Purpose and use of borrowing is to acquire pref shares of Acquisitionco having a dividend rate > interest rate on borrowing. ...

Reasons: Increase in combined contributions by employee & employer to a limit of 18% of pensionable earnings (as defined in registered pension plan) in actual cash contributions to RPP and in notional employer contributions to unfunded plan does not cause the unfunded plan to become a salary deferral arrangement. ...

(See 970979, 960375 & 952312.) The prospectus exemptions provided for “sophisticated purchasers” and “block sales” under the QSA are very similar to the private placement exemption under the OSA. ...

The investment objectives of the Trust are: (i) to generate a relatively stable increase in the net asset value of the Trust; (ii) to ensure that the performance of the Trust is substantially independent of the major fixed income and equity markets; (iii) to achieve a low volatility; and (iv) to distribute to Unitholders at least XXXXXXXXXX ¢ per Unit of the net assets of the Trust at each quarter end. ...

Pourvu que les conditions énoncées à l’alinéa 110(1)d) de la LIR soient respectées, l’employé visé aura droit à la déduction de 25 % prévue à cet alinéa à l’égard de la totalité du montant en espèces qui sera reçu par l’employé à la suite de l’exercice de son droit de recevoir la valeur économique de ses options. ...

XXXXXXXXXX 973377 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 1998 Dear Sirs: Re: Advance Tax Ruling XXXXXXXXXX ("Opco")- Account # XXXXXXXXXX- Phantom Stock Plan This is in reply to your letters of XXXXXXXXXX, in which you request an advance income tax ruling on behalf of the above-named taxpayer. ...