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In document # 9703377, we indicated that "for purposes of paragraph 20(1)(f) the principal amount under the terms of the CBL (Consumer Based Loan) is the total amount paid on maturity plus the total of all payments in satisfaction of principal paid over the life of the obligation. ...

Reasons: Similar to ruling # E 2001-0079143. XXXXXXXXXX 2002-016141 XXXXXXXXXX, 2002 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX, in which you requested an advance income tax ruling in respect of the income tax consequences arising from the proposed transactions described below. ...

In document # 9703377, we indicated that "for purposes of paragraph 20(1)(f) the principal amount under the terms of the CBL (Consumer Based Loan) is the total amount paid on maturity plus the total of all payments in satisfaction of principal paid over the life of the obligation. ...

In document # 9703377, we indicated that "for purposes of paragraph 20(1)(f) the principal amount under the terms of the CBL (Consumer Based Loan) is the total amount paid on maturity plus the total of all payments in satisfaction of principal paid over the life of the obligation. ...

The Pubco Notes will have a XXXXXXXXXX-year term and annual interest rate of approximately XXXXXXXXXX %, payable semi-annually. ...

B Co's audited consolidated financial statements for the year ended XXXXXXXXXX indicate that B Co had, on a consolidated basis: Long-term debt of approximately $ XXXXXXXXXX; A weighted average rate of borrowing on the long-term debt of XXXXXXXXXX%; Shareholders' equity of approximately $XXXXXXXXXX; and Short-term notes payable of approximately $XXXXXXXXXX. ...

February 25, 2003 XXXXXXXXXX TSO HEADQUARTERS Business Enquiries Financial Institutions Section Verification & Enforcement Division Income Tax Rulings Directorate Attention: XXXXXXXXXX Alison Campbell (613) 957-3496 2003-000167 Demutualization Payments to Employees We are replying to your request for assistance in determining the appropriate application of section 139.1 of the Income Tax Act, in respect of a particular taxpayer. ...

Consequently, its four founding shareholders currently own the common shares of Lossco as follows: Shareholder # of common shares Country of Residence Profitco XXXXXXXXXX Canada Forco1 XXXXXXXXXX United States XXXXXXXXXX ("Forco2") XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX ("Forco3") XXXXXXXXXX XXXXXXXXXX Profitco's aggregate adjusted cost base and aggregate paid-up capital attributable to its XXXXXXXXXX common shares of Lossco is $XXXXXXXXXX. 5. ...

"investment tax credit" " has the meaning assigned to that expression by subsection 127(9) of the Act. ...

These shares represented XXXXXXXXXX % of the issued and outstanding share capital of XXXXXXXXXX, respectively. 7.1 XXXXXXXXXX. 7.2 XXXXXXXXXX. 7.3 XXXXXXXXXX. 7.4 XXXXXXXXXX. 8. ...