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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, and, unless otherwise stated, every reference herein to a Part, section, subsection, paragraph or subparagraph is a reference to the relevant provision of the Act; (b) "Canadian resource property" has the meaning assigned by subsection 66(15); (c) "CCOGPE" means "cumulative Canadian oil and gas property expense" within the meaning assigned by subsection 66.4(5); (d) "COGPE" means "Canadian oil and gas property expense" within the meaning assigned by subsection 66.4(5); (e) "GOR agreement " means the agreement described in paragraphs 5, 6 and 7 below between Petroleum Co. and the resource company, and which will be substantially similar to the Royalty Agreement dated XXXXXXXXXX that was provided with your advance income tax ruling request; (f) "Grantor of the GOR agreement" is the resource company that is party to the GOR agreement with Petroleum Co.; and (g) "Petroleum Co. ...

Principal Issues: Variation of a trust with unborn beneficiaries- can a Saunders & Vautier variation be made? ...

., Verification & Enforcement Division M.P. Sarazin (613) 824-5441 Attention: Naomi Tsuji 2000-003500 Salary Deferral Arrangement We are writing to you in response to John Gordon's memorandum of June 27, 2000, wherein he requested our views as to whether a specific employee incentive plan would constitute a salary deferral arrangement for purposes of the Income Tax Act (the "Act"). ...

More specifically, you have requested our comments regarding question # 2 on form T2200 regarding whether you normally require the employees to work away from your place of business, or in different places. ...

August 28, 2000 XXXXXXXXXX Tax Services Office HEADQUARTERS Verification & Enforcement Division S. ...

In addition, lock-up agreements (which the parties called "Voting Agreements") were entered into at various times on or before XXXXXXXXXX between (i) Buyco and Holdco, and (ii) XXXXXXXXXX shareholders and/or optionholders of Target who, in the aggregate, hold approximately XXXXXXXXXX % of the shares of Target, but none of whom individually owns, directly or indirectly, or exercises control over, more than 10% of the common shares of Target. ...

These rulings are given subject to the limitations and qualifications set forth in Canada Customs & Revenue Agency (the "Agency") Information Circular 70-6R3 dated December 30, 1996, and are binding upon the Agency provided the Plan is implemented on or before XXXXXXXXXX. ...

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

Principal Issues: An individual's professional corporation will sell XXXXXXXXXX % of its practice to another professional corporation and the individual will resign from the professional corporation and will carry on the balance of the professional corporation's business as a sole proprietor, can the individual's professional corporation pay the individual a retiring allowance? ...

To the extent that it relates to a past transaction you should contact the appropriate Tax Services Office of the Canada Customs & Revenue Agency (the "CCRA"). ...