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September 13, 2001 Toronto East TSO HEADQUARTERS Small/Med Business Audit Shaun Harkin, CMA Verification & Enforcement (613) 957-9229 Attention: Mike Bolton Trust and Pension Section 2001-008306 XXXXXXXXXX Health and Welfare Trust ("HWT") This is in reply to your memorandum dated May 4, 2001 in which you asked for our comments on the acceptability of the above named trust agreement, which accompanied your letter, as a HWT. ...

The response to question two at the 1993 Canadian Tax Federation Revenue Canada Round Table states in part: "... ...

We would note that comments in the above Technical Guide concerning eligible / ineligible assets of "systems" or "enhanced combined cycle systems" qualifying under paragraph (c) to Class 43.1, indicate that not all assets associated with Qualifying Equipment are considered eligible assets, i.e., not all of such assets should be considered "ancillary to" such equipment for purposes of subparagraph (a)(iv) to Class 43.1. ...

Principal Issues: Various issues on sojourning Position: see memo attached Reasons: see memo attached July 9, 2001 International Tax Directorate International Section Rene Fleming, Manager Tim Kuss Policies & Publications Section 957-2117 Policy and Programs Division Attention: Ved Arora 2000-004761 Paragraph 250(1)(a)- Sojourning in Canada You have requested our views with regard to certain issues raised by XXXXXXXXXX, regarding the applicability of paragraph 250(1)(a) to determine the residence status of certain airline pilots employed by a Canadian resident airline. ...

The recent dividend history of the common shares of Pubco is as follows: Fiscal Year Annual Dividends Per Share* XXXXXXXX XXXXXXXXXX XXXXXXX XXXXXXXXXX XXXXXXX XXXXXXXXXX XXXXXXX XXXXXXXXXX XXXXXXX XXXXXXXXXX XXXXXXX XXXXXXXXXX XXXXXXX XXXXXXXXXX * restated to reflect a stock dividend paid XXXXXXXXXX 4. ...

Definitions and Abbreviations In this letter, the following terms have the meanings specified: (a) "Act" means: the Income Tax Act, R.S.C. 1985 (5th Supp.) c.1, as amended to the date hereof; (b) "CCRA" means: the Canada Customs and Revenue Agency; (c) "Corporation " means: XXXXXXXXXX; (d) "Corporation A" means XXXXXXXXXX, which is a taxable Canadian corporation for purposes of the Act; (e) "Corporation B" means XXXXXXXXXX, the U.S. parent of Corporation A; (f) "Employee" means: XXXXXXXXXX; (g)"Options" means the outstanding options issued to the employee by Corporation B in accordance with the terms of the Plan; (h) "Plan" means: means the XXXXXXXXXX; (i) "Regulations" means: The Income Tax Regulations; and (j) "Share" means: means a common share of Corporation B. ...

Subsection 98(3) of the Act states in part: "... a Canadian partnership has ceased to exist and all the partnership property has been distributed to persons who were members of the partnership immediately before that time so that immediately after that time each such person has, in each such property, an undivided interest that, when expressed as a percentage (in this subsection referred to as that person's "percentage") of all undivided interests in the property, is equal to the person's undivided interest, when so expressed, in each other such property... ...

May 17, 2002 Audit Directorate HEADQUARTERS Anne Wilson Wayne Antle, CGA Manager (613) 957-2102 Technical Applications & Valuations Division 2002-013954 Transfer of Professional Income to a Corporation This is further to your email of May 8, 2002, concerning our decision not to revise our position on the transfer of professional income to a professional corporation, despite the decision of the Tax Court in the case of Jerome Wallsten and Lakeside Properties Ltd. v. ...

& 2.) In our document 9619803 dated XXXXXXXXXX, 1996, which the taxpayer's representative has referred to, we provided rulings in respect of a supplemental retirement arrangement ("SRA") that was similar in design to the plan in question here. ...

If you have further interpretative issues regarding residence status determinations, or if you have comments or questions with respect to IT-221R3, please write to the International & Trusts Division of this Directorate. ...