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Civil Law Trust Richard Tremblay and Kim Wharram (footnote 11) summarize the most important characteristics of a civil law trust as follows: “… articles 1256 to 1298 of the new Civil Code of Quebec… now provide for a comprehensive trust regime that includes provisions for transfers of property to a trustee, and the administration of the trust property by the trustee… While this trust regime contains many concepts that are similar to common law principles relating to trusts, there are some notable distinctions. ... For Director International & Trusts Division Income Tax Rulings Directorate FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 We do not know whether XXXXXXXXXX acted pursuant to the directions of XXXXXXXXXX. 2 However, at this time, XXXXXXXXXX was the Supervisor and per Article XXXXXXXXXX of the Articles of the Foundation, only XXXXXXXXXX could have appointed a new Supervisor. 3 We did not assess the Canadian income tax consequences of the change in Beneficiaries of the Foundation. 4 However, we question whether, pursuant to the laws of the Netherlands Antilles, a person can be the Founder (i.e. ...

After degassing, the emulsion will be cooled through a heat exchanger to approximately XXXXXXXXXX ° C. (iv) Emulsion Treating System: The water content in the bitumen will typically be less than XXXXXXXXXX % as the bitumen leaves the production separation system and is split into two streams that feed the XXXXXXXXXX treaters. ...

All of the authorized Series A Preferred Shares are issued and outstanding and are owned by XXXXXXXXXX ULC. 10) The Series A Preferred Shares have the following attributes: a) redeemable and retractable no sooner than XXXXXXXXXX years after the day following the date of issue for an amount (the "Redemption Amount") equal to $XXXXXXXXXX US in aggregate; b) voting, with a fixed cumulative annually-compounding dividend equal to XXXXXXXXXX % of the Redemption Amount plus any unpaid dividends from all prior years- no dividend may be paid on any other class of shares which would impair US Opco's ability to redeem the Series A Preferred Shares at the Redemption Amount. 11) The ACB of the Series A Preferred Shares is equal to the elected amount that was claimed under a section 85 election in respect of the transfer of XXXXXXXXXX Foreign Affiliates by XXXXXXXXXX ULC to US Opco at the time of the issuance of the shares. ... PROPOSED TRANSACTIONS Sale of Series A Preferred Shares 23) Prior to XXXXXXXXXX,XXXXXXXXXX ULC will sell a minimum of XXXXXXXXXX % of the Series A Preferred Shares of US Opco to US Subco for proceeds of disposition equal to the then fair market value of the shares. ...

Subco is a taxable Canadian corporation, XXXXXXXXXX % of the shares of which were, prior to XXXXXXXXXX, owned by Targetco1. ... The XXXXXXXXXX % of the shares of Subco have, at all times, been owned by a person dealing at arm's length with Targetco1 and Aco. 5. ...

The Sub-Fund1 Units and the Sub-Fund2 Units will not have any voting rights except the right, on written notice signed by Unitholders holding XXXXXXXXXX % of the units of Sub-Fund1 and Sub-Fund2, to require the Manager to resign. ... Yours truly, for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

For the purposes of the Plan, the Company shall convert Earnings received in a currency other than the lawful currency of Canada into the lawful currency of Canada using an appropriate methodology selected by the Company and used consistently from year to year; (i) "Effective Date" means: the date as of which the Initial Letter of Credit is to be issued; (j) "Employee" means: a person who is employed by an Employer; (k) "Employer" means: the Company or a company that is affiliated or associated with the Company that is designated by the President or any XXXXXXXXXX Directors of the Company, as an Employer, provided such company adopts the Plan and agrees to make the Notional Employer Contributions required under the Plan in respect of its Employees; (l) "Event of Default" means: an occurrence of an event, as specified in the Trust Agreement, which requires the Trustee to demand payment under a letter of credit; (m) "Initial Letter of Credit" means: a Letter of Credit as described in 29 below; (n) "Investment Options" means: the notional investment options described in 10 below; (o) "Notional Account" means: an account described in 7 below; (p) "Notional Employer Contributions" means: notional contributions as described in 7, 8 and 23 below, as applicable, that are made to a Plan Member's Notional Account by the Plan Member's Employer; (q) "Notional Investment Earnings" means: the notional amount of investment income credited to a Plan Member's Notional Account pursuant to the provisions described in 7 below; (r) "Plan" means: before the proposed transactions, the "XXXXXXXXXX ", sponsored and maintained by the Company, as described in 3 through 18 below, and after the proposed transactions, the "XXXXXXXXXX " as described in 3 through 18 and 19 through 27 below; (s) "Plan Member" means a DC Member or a TCN Member, as applicable. ...

The distribution is determined annually by approval of not less than XXXXXXXXXX % of the Partners. ... (e) Upon the death of a Partner, the deceased Partner's partnership interest is forfeited and the deceased Partner's estate is entitled to XXXXXXXXXX % of the Partner's Tax-Paid Capital and any distributable but unpaid profits allocated to the deceased Partner in respect of the portion of the current or prior fiscal periods preceding death. ...

Negotiations are ongoing and while a final draft of the purchase and sale agreement is not currently available, it is anticipated that the final form of the purchase and sale agreement for the Target Shares, which will be governed by the law of XXXXXXXXXX, will include the key terms as described in paragraphs 3.2 to 3.10 below. 3.2 The Vendor and the Purchaser will agree that at Closing, the Target will not hold the Excluded Assets, nor will it be responsible for the Excluded Liabilities. 3.3 The Purchase Price will be equal to approximately XXXXXXXXXX and will consist of the following components: (a) XXXXXXXXXX payable in cash at Closing; (b) an amount equal to the amount of the Surplus Assets, payable at or immediately following Closing in cash, cash equivalents or a combination thereof (in Purchaser's sole discretion); (c) XXXXXXXXXX payable in cash no later than the XXXXXXXXXX anniversary following the Closing, and (d) XXXXXXXXXX (which is anticipated to constitute a significant percentage of the Purchase Price) payable without interest in cash, in quarterly amounts, commencing for the quarter ended XXXXXXXXXX and for each full quarter thereafter, payable no later than XXXXXXXXXX days following the last date of each quarter, with each such payment to be in an amount that is equal to XXXXXXXXXX % of the Quarterly Additional Product Consideration for such quarter. 3.4 Notwithstanding the payment terms set forth in paragraph 3.3(d) above, upon at least XXXXXXXXXX business days' written notice to the Vendor, at any time or from time to time, as applicable, the Purchaser or an affiliate thereof may pay the Vendor any or all of the balance of the Obligation not previously paid to the Vendor based on the Quarterly Additional Product Consideration pursuant to paragraph 3.3(d). ... In other words, the Purchase Price will be reduced by the unpaid amount of the Obligation if the cumulative amount of the Quarterly Additional Product Consideration received by the Target and/or any successor or permitted assignee thereof (XXXXXXXXXX % of which is paid or payable to the Vendor under paragraph 3.3(d) above) during the period ending on the Threshold Anniversary is less than the Threshold Amount. ...

Other decisions with respect to the following matters require the approval of XXXXXXXXXX % of the Partners present: (i) any amendment to the Partnership Agreement; (ii) any amendment to the Income Distribution Plan; (iii) the admission of a new Partner; and (iv) the expulsion of a Partner. ... (e) A quorum of XXXXXXXXXX % of all Partners is required at a duly constituted business meeting with respect to any decisions of the Partners. ...

.), the Federal Court-Trial Division considered the meaning of the term "... an amount has become payable to a taxpayer in a taxation year... ... In Mid-West Abrasive Company, the Court looked to the surrounding words and stated: "... 'In respect of the year' refers, in my opinion, to the year during which the borrowed money was used and not the year in which the lender chose to make the request for interest... ...