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The foregoing computation of the purchase price per Unit payable by ParentCo in shares of its capital stock is subject to subsection 25(3) of the CBCA, which provides: " A share shall not be issued until the consideration for the share is fully paid in money or in property or past services that are not less in value than the fair equivalent of the money that the corporation would have received if the share had been issued for money. ...

Principal Issues: 1. whether LP Units are tax shelters 2. whether existence of call option causes no REOP 3. whether existence of call option is 96(2.2)(d) benefit 4. whether gaar applies 5. whether, where a trust receives mixed income (split and nonsplit), trust may designate payments to beneficiaries Position: 1. no 2. not in and of itself 3. not in and of itself 4. maybe, if call option is exercised and 24 month period in 110.6(2.1) avoided 5. yes, as long as nonsplit income allocated to beneficiaries does not exceed non-split income of trust Reasons: 1. limited partners cannot receive cumulative losses that are greater than XXXXXXXXXX % of their capital contribution 2. must consider all facts re REOP 3. call option is at discretion of general partner, not limited partners/ option price is fmv 4. 110.6 5. law does not prohibit streaming or require equal payouts of split and nonsplit income XXXXXXXXXX 2001-006921 XXXXXXXXXX, 2001 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX We are writing in response to your letter of XXXXXXXXXX, wherein you requested an advance income tax ruling, and your subsequent correspondence and our (XXXXXXXXXX) telephone discussions concerning this ruling request. ...

.), as amended, and unless otherwise stated, every reference herein to a section, subsection, paragraph or subparagraph is a reference to the relevant provision of the Act; (b) "adjusted cost base" (also referred to as "ACB") has the meaning assigned by section 54; (c) "agreed amount" in respect of property means the amount that the transferor and the transferee of the property have agreed upon in their election under subsection 85(1) in respect of the property; (d) "BCA" means the "Canada Business Corporations Act "; (e) "capital dividend" has the meaning assigned in subsection 83(2); (f) "capital dividend account" (also referred to as "CDA") has the meaning assigned by subsection 89(1); (g) "capital property" has the meaning assigned by section 54; (h) "cost amount" has the meaning assigned by subsection 248(1); (i) "dividend refund" has the meaning assigned by subsection 129(1); (j) "eligible property" has the meaning assigned by subsection 85(1.1); (k) "Mr.A" refers to the late XXXXXXXXXX; (l) "Mrs. ...

In general, this means that XXXXXXXXXX % of an Eligible Director's retainer fees for a year and meeting fees for meetings held within a Quarter in that year become payable at the end of the Quarter. ...

If the Eligible Director elects to participate in the Plan, he or she may choose to receive: (i) XXXXXXXXXX%, (ii) XXXXXXXXXX %, (iii) XXXXXXXXXX% or (iv) XXXXXXXXXX% of his or her Directors' Annual Remuneration in DSUs under the Plan, with the remainder (if any) of such Directors' Annual Remuneration to be paid in cash, net of the applicable withholding taxes, to the Eligible Director. ...

The capital gain on the deemed disposition of XXXXXXXXXX shares at the time of death was $ XXXXXXXXXX and the adjusted cost base of the XXXXXXXXXX Holdings Class A shares to the Estate is $XXXXXXXXXX. ...

The partners of Partnership A and their interests in Partnership A are Company A (XXXXXXXXXX %), Company B (XXXXXXXXXX%) and Company C (XXXXXXXXXX%) and Company A1 (XXXXXXXXXX%). ...

It is also to be noted that in cases involving theatrical shows where performances were given in different places, both the U.S. and New Zealand, which Tax Conventions use the same concepts of "permanent establishment" and "fixed base" as that found in the Convention, denied that a permanent establishment existed (see technical interpretation # E 2000-0036167). ...

Reasons: Similar to ruling # E 2001-0079143 and E 2002-016141 XXXXXXXXXX 2002-016338 XXXXXXXXXX, 2002 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request XXXXXXXXXX This 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. ...

Definitions In this letter, unless otherwise indicated, all statute references are to the Income Tax Act and Regulations, R.S.C. 1985 (5th supp.) c. 1, as amended (the "Act"), and the following terms have the meaning specified: "Amalco" means the corporation that will result from the amalgamation of XXXXXXXXXX Following the amalgamation, XXXXXXXXXX% of the voting shares will be owned indirectly by XXXXXXXXXX and persons related to him and XXXXXXXXXX % of the voting shares will be owned indirectly by XXXXXXXXXX and persons related to him. ...