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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. ...

However, in response to question # 20 at the 1994 Association de Planification fiscale et financière (APFF) Conference Round Table, CCRA explained that: Interpretation Bulletin IT-114, issued in 1973, was cancelled in full because it did not reflect significant changes to the Income Tax Act and was no longer a useful guide to the taxation of discounts, premiums and bonuses relating to a multiplicity of financial products that have changed considerably. ...

Murphy Manager Trusts Section International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch c.c. ...

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. ...

July 8, 2002 XXXXXXXXXX Income Tax Rulings Verification & Enforcement Division Directorate XXXXXXXXXX Bob Naufal (613) 957-2744 2002-014164 XXXXXXXXXX This is in response to your memo dated May 14, 2002, wherein you requested our comments as to whether Pre-1994 Section 79 ("Former Section 79") or Section 80 ("Former Section 80") would apply to the above-mentioned Taxpayer. ...