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" You advised in your aforementioned letter: "... a number of meetings were held between industry representatives and representatives of the Department of Finance in order to broaden the transitional relief...Ultimately, it was agreed that one of the criteria would be that the production services limited partnership had begun incurring production expenses prior to September 18, 2001. ...

Our comments in # 1 above would have application to this situation. 5) Our position concerning arrangements whereby employees are able to select the type and level of coverage from a menu of available benefits (sometimes referred to as "cafeteria plans" or "flexible benefit programs") is discussed in Interpretation Bulletin IT-529, "Flexible Employee Benefit Programs". ...

If the "Total Shareholder Return" exceeds the Benchmark and is in the top quartile at the end of the third year of the Plan, then all Share awards will vest at that time and an additional XXXXXXXXXX % of the original number of Shares awarded will be added; b. ...

The collection is effected by deeming a dividend to have been paid to the non-resident insurer that is subject to withholding tax at a rate of 25 % under Part XIII of the Act. ...

., e.g. a church, school, college, hospital, asylum, reformatory, mission or the like; [...] ...

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

" 7. Paragraph 36 will be amended to read as follows: Oco will redeem all of its Oco XXXXXXXXXX Shares held by Cco for an amount equal to their fair market value, being the Oco XXXXXXXXXX Aggregate Redemption Amount. ...

Funds qualified before proposed transactions & proposed transactions will not disqualify. ...

Holdco1 holds XXXXXXXXXX Common Shares (XXXXXXXXXX%), Holdco2 holds XXXXXXXXXX Common Shares (XXXXXXXXXX%), the Employees hold XXXXXXXXXX Common Shares (XXXXXXXXXX%), and Holdco3 holds the remaining XXXXXXXXXX Common Shares (XXXXXXXXXX %). ...

These rulings are provided subject to the limitations and qualifications set out in Information Circular 70-6R4 issued by the Canada Customs & Revenue Agency on January 29, 2001 and are binding upon the Agency provided that the proposed transactions are completed on or before XXXXXXXXXX. ...