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As a result, we are of the opinion that US Holdco satisfies paragraph 3 of Article XXIX A (LOB) and can benefit from the reduced rate of Canadian withholding tax in Article X of the Treaty, provided that US Holdco satisfies the conditions in Article X of the Treaty. for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch c.c. ...

DSUs allocated to a Participant under the Plan will vest in XXXXXXXXXX % increments over a XXXXXXXXXX-year period starting with the end of the first XXXXXXXXXX-month period following the date of grant. ...

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

Yours truly, for Director Reorganizations and Resources Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

Yours truly, XXXXXXXXXX Section Manager For Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

In addition to the foregoing, prior to his death, the deceased had invested in a new limited partnership, which raised funds to invest in flow-through shares of various mining and oil & gas resource corporations. ...

Yours truly, Sandy Parnanzone For Director, Business and Partnerships Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...