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You posed this question: With the introduction of section 80.4(1.1)(b), to the extent evidence clearly exists that " it is reasonable to conclude that...the debt would not have been incurred" were it not for the employee's relocation, notwithstanding the introduction of section 6(23), would the taxable benefit under such arrangements be computed in accordance with the provisions of section 80.4? ...

Paragraph 9 of D13-1-3 highlights the fact that we are dealing with two very different pieces of legislation when it states, "... where it is determined that a business entity is a resident, carrying business, or maintaining a permanent establishment in Canada for valuation purposes, this, in itself, in no way establishes that the entity would be considered to be a resident, carrying on business, or maintaining a permanent establishment in Canada for the purposes of the Income Tax Act.... ...

Prepared by: Tim Kuss Date: November 1999 Control # 992963 ...

Yours truly, for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

Harding A/Manager, Policy & Technical Services 957-8953 Trust Accounts Division Attention: Lloyd MacKay 2000-001003 Retirement Compensation Arrangements ("RCAs") This is in reply to your memorandum of February 23, 2000, in which you asked us to respond to comments received by you with respect to our memorandum to you dated January 17, 2000, (our file 1999-001524). ...

It is anticipated that XXXXXXXXXX other First Nations located in XXXXXXXXXX will become limited partners of LP1 and will each acquire a XXXXXXXXXX % interest in the partnership. ...

To the best of your knowledge, and that of the taxpayer involved, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayer or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or a related person; (iii) under objection by the taxpayer or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...

Immediately after the Shares are issued under the proposed transaction, Annuitants will own (and will be deemed to own by virtue of the definition of "specified shareholder" in subsection 248(1), paragraphs (a) and (b)) Shares as follows: RRSP Shareholders Fraction of Share Owned % Company Owned XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX PURPOSE OF THE PROPOSED TRANSACTION 13. ...

Troy of the North York Tax Services Office (file # 962478) concerning the same issue, such response will be amended to reflect our position described above. ...

Principal Issues: In the definition of "permanent establishment" in paragraph 400(2)(a) of the Income Tax Regulations, do the words " a fixed place of business" mean a fixed place of business in Canada? ...