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For purposes of the Guidelines, “employer is resident on a reserve” means: “… that the reserve is the place where the central management and control over the employer organization is actually located. ...

Cette allocation est imposable à moins de faire partie des exceptions énumérées aux sous-alinéas 6(1)b)(i) à (ix) de la Loi de l'impôt sur le revenu (ci-après la «Loi »). ...

The Fund directly holds all of the outstanding units and notes of XXXXXXXXXX Trust, and indirectly holds limited partnership units of XXXXXXXXXX LP (representing approximately XXXXXXXXXX % of the outstanding limited partnership units of XXXXXXXXXX LP), all of the shares of GP Co (the sole trustee of the Trust, being the general partner of XXXXXXXXXX LP and Holdings LP), and all of the shares of Beneficiary, the sole beneficiary of the Trust. 3. ... However, advances evidenced by the Sub-Loan Note will bear interest at a rate of XXXXXXXXXX % per annum in excess of the interest rates under the New Credit Facility. 30. ...

Partnership will assume the O & M Agreement such that the XXXXXXXXXX Assets will be operated in substantially the same manner a before their transfer to Partnership. 18. ... It is not anticipated that any prospective Debenture Holder will hold more than XXXXXXXXXX % of the units of Income Fund. ...

XXXXXXXXXX prior ruling (file # 972815) re: identical transaction (transaction was not completed). 2. ... On the Redemption Date, ACO will be required to make a cash payment equal to the Redemption Price to those Holders who surrender their Units for redemption. g) If a Fundamental Change of Control (as defined below) of BCO occurs, each Holder will have the right, at the Holder's option, to require ACO to purchase all or any part of the Holder's Units on the date (the "Repurchase Date") that is XXXXXXXXXX days after the date ACO gives notice of the Fundamental Change of Control at a price (the "Repurchase Price") equal to XXXXXXXXXX % of their Principal Amount plus accrued Interest to the Repurchase Date, after which the related Warrants will automatically expire. ...

Note " means the interest-bearing promissory note in the principal amount of USD$XXXXXXXXXX issued by ULC to U.S. ... Yours truly, XXXXXXXXXX Section Manager For Division Director International Section I Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

On XXXXXXXXXX, Eco used part of its excess funds to make an interest free loan of $ XXXXXXXXXX to Cco (the “Cco Loan”). 20. On XXXXXXXXXX, Cco, with the proceeds from the Cco Loan, made an interest free loan of $ XXXXXXXXXX to Aco (the “Aco Loan 2”). ...

., c. 95, as amended; (bb) “Stock Exchange” means the XXXXXXXXXX; (cc) “Sub-Custodian” means XXXXXXXXXX; (dd) “Sub-Custodian’s Parent” means XXXXXXXXXX; (ee) “subsidiary wholly-owned corporation” has the meaning assigned by subsection 248(1) of the Act; (ff) “Tax Treaty” has the meaning assigned by subsection 248(1) of the Act; (gg) XXXXXXXXXX; (hh) “TLCA” means the Trust & Loans Companies Act (S.C. 1991, c. 45); (ii) “Unit(s)” means a unit of account, representing a proportionate undivided co-ownership interest in the assets of the Fund, as tenants in common with the other Unitholders. ... The executive partners own XXXXXXXXXX % of the Investment Manager with the remaining XXXXXXXXXX% owned by investors. ...

The explanatory notes to paragraph 20(1)(e) state: Paragraph 20(1)(e) is amended to clarify that it does not allow a deduction for profit participation and similar payments — that is, payments dependent on the use of or production from property, or computed by reference to revenue, profits, cash flow, commodity prices or any other similar criterion or by reference to dividend payments. Where such payments are compensation for the use of borrowed money or for the right to pay a debt over time, they would be excluded by the existing paragraph 20(1)(e) — either because they are interest or because they fall within the broad definition of “principal amount” in subsection 248(1). ...