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Any reductions of Shares acquired through the Plan will have to be approved by the Chairman & CEO of the Company, subject to the requirements of subparagraphs 4(j), (m) and (n) above. ...

All payments under the forward contracts will be linked to the investment returns of the appropriate Underlying Fund and will be governed by the following terms: (a) each Fund will pay transaction costs to the Counterparty as required under the forward contract which are initially anticipated to approximate the Counterparty's bankers' acceptance rate plus approximately XXXXXXXXXX % of the nominal value of the forward contracts; (b) if the net asset value of the Underlying Fund increases, the Counterparty will pay the Fund an amount equal to the increase in the exposure under the forward contracts; and (c) if the net asset value of the Underlying Fund decreases, the Fund will pay the Counterparty an amount equal to the decrease in the exposure under the forward contract. 10. ...

Yours truly, Kimberley Wharram Acting Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 For the present purposes, the word “primarily” means more than 50%. 2 C.R.C. c. 945, as amended. 3 R.S.C. 1985, c. 1 (5th suppl.) as amended. 4 The following property only qualifies for an inclusion in Class 43.1: (i) mid-efficiency, fully or partially fossil-fuelled cogeneration systems; (ii) electric vehicle charging stations set up to supply more than 10 kW but less than 90 kW of continuous power; and (iii) electrical energy storage equipment connected to one of the above systems and stand-alone electrical energy storage systems meeting particular efficiency requirements. 5 See paragraphs (b) and (e) of Class 43.1. 6 During the phase-out period the enhanced CCA rates are as follows: for eligible properties that are available for use in: 2024 and 2025 the rate is 75%; 2026 and 2027 the rate is 55%; and 2028 the enhanced CCA rate is nil. 7 See generally, Tenneco Canada Inc. v The Queen, 91 D.T.C. 5207 (F.C.A.) and more recently, Canada v. ...

ITRD has generally accepted that share appreciation rights (“SAR”) plans of the type described in ATR-45 – “Share Appreciation Rights Plan” would not be SDAs (“ATR-45 SAR Plans”). ...

13 November 2020 Internal T.I. 2020-0864831I7- Equity award plan and recharge agreement Unedited CRA Tags 7(3)(b), 248(1) “salary deferral arrangement”, 20(1)(oo), 15(1), 212(2)(a), 214(3)(a), 246(1) * Principal Issues: 1. ...

XXXXXXXXXX 2021-087667 XXXXXXXXXX, 2021 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request – Transfer between U.S. pension plans XXXXXXXXXX This is in reply to XXXXXXXXXX email of XXXXXXXXXX requesting that we resume our consideration of the request for an advance income tax ruling (“Ruling”) on behalf of the XXXXXXXXXX that was originally submitted in XXXXXXXXXX letter of XXXXXXXXXX. ...

The question and answer was reviewed by John Kurrant, Oil & Gas Specialist on June 12 and he said that he does not have any concerns. ...

The maximum CCA which Corporation AC may claim in respect of its 1988 taxation year is computed per paragraph 1100(l)(ta) of the Regulations as follows: An amount not exceeding the aggregate of: i) the aggregate of A) the lesser of Subtotals Totals i) 50% of the capital cost of designated property acquired in the year (50% of XXX) ii) UCC in respect of designated property acquired by virtue of specified transaction B) 25% of the lesser of I) UCC not including designated property acquired during the year II) capital cost of non-designated property acquired during the year Subtotals ii) the lesser of A) excess of UCC over capital cost of all property acquired in the year NIL B) an amount equal to the aggregate of I) 50% of capital cost of property acquired in preceding years NIL II) excess from clause A over amounts related to prior years NIL NIL NIL Available CCA as at June 30, 1988 for Corporation AC $86,562.50 ========== These comments represent our opinion of the law as it applies generally. ...

" Le terme "taxes'" est définie aux fins de l'application du paragraphe 23(2) de la Loi sur la gestion des finances publiques au paragraphe 23(1) de cette même loi 23. (1) Les définitions qui suivent s'appliquent au présent article. (...) ...

At the lower court level it was found that to constitute an amount receivable "... it was not enough to have a precarious right to receive the amount in question, but he must have a clear legal, though not necessarily immediate, right to receive it". ...