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5 December 2005 External T.I. 2005-0155331E5- XXXXXXXXXX 2006 Meeting- Q & A's Unedited CRA Tags 18(4) 95(6) Principal Issues: Questions & Answers provided by Wayne Adams at 2006 XXXXXXXXXX Meeting Limited partnerships and thin capitalization Various questions re 95(6) Reverse hybrids and treaty Position: See body of memo Reasons: See body of memo On October 24, 2006, Wayne Adams, Director General of the Income Tax Rulings Directorate, Canada Revenue Agency, attended the XXXXXXXXXX meeting and responded to the following questions: 1. ... The judgment contained the following relevant passage: ".. I am not prepared to say that because a U.S. tax saving that is greater than the Canadian tax saving is envisaged or achieved by a Canadian tax avoidance scheme this in itself takes the transaction outside the ambit of section 245. ...

15 June 1998 External T.I. 9706295- AFFILIATED PERSONS & ESTATE OF DECEASED Unedited CRA Tags 40(3.6) 164(6) 112(3.2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Basically: – two individuals are considered to be affiliated only where they are spouses of one another; – Corporations are affiliated to three groups of persons: 1. the person who controls the corporation; 2. members of an affiliated group of persons who control the corporation where an affiliated group is a group of persons each member of which is affiliated with every other member; and lastly the spouses of persons of either of the first two categories. ...

None of the OwnerCos has a permanent establishment in Canada as defined under Article V of the Canada-US Tax Convention (the “US Treaty”) or Article 5 of the Canada – UK Tax Convention (the “UK Treaty”). 6. ... Given the above analysis, it is our view that Fee #2 is a “royalty” as it qualifies as “payments … for the use of, or the right to use, any … information concerning industrial, commercial or scientific experience…” as defined under paragraph 4 of Article XII of the US Treaty. ... As discussed above, we have concluded that Fee #2 paid by CanCo to OwnerCo is for “the use of, or the right to use, … any information concerning industrial, commercial, or scientific experience…”. ...

Parent B is a XXXXXXXXXX % limited partner in Parent A, GP is a XXXXXXXXXX % general partner in Parent A and XXXXXXXXXX is a XXXXXXXXXX limited partner in Parent A. ... On XXXXXXXXXX, Parent B exercised through its wholly owned subsidiary, BCo, the Option by acquiring from ACo XXXXXXXXXX % of the units of AB Partnership. As a result, BCo now owns XXXXXXXXXX % of the issued and outstanding units of AB Partnership, while ACo owns the remaining XXXXXXXXXX % of the issued and outstanding units of AB Partnership. ...

13 October 2004 Internal T.I. 2004-0060441I7- Hedging Gains / Losses of Partnership Unedited CRA Tags 20(1)(v.1) Reg 1206(3) Reg 1210(3) Principal Issues: Whether gains / losses realized by a partnership from a hedging activity may qualify for inclusion in the determination of the adjusted resource profits of a member of the partnership. Position: Yes, provided the hedging relates to qualifying production of the partnership such that the gains / losses would be included in the adjusted resource profits of the partnership but only the extent of the members share of such profits. ... Cameron Christine Savage (613) 347-1361 Co-ordinator, Resource Industries Attention: Zul Ladak 2004-006044 Hedging Gains / Losses of Partnership We are writing in response to your query regarding our memorandum dated December 9, 2003, wherein we provided comments in regard to certain Oil & Gas Audit Issue Sheets (our file 2003-00297). ...

7 November 1990 Income Tax Severed Letter- Manufacturing & Processing Profits Deduction Unedited CRA Tags 125.1, IT-145R Subject: XXX Manufacturing & Processing (“M&P”) Profits Deduction We are writing in reply to your memorandum of April 19, 1990, wherein you requested our comments as to whether or not the activities of the above-noted taxpayer qualify for the M&P profits deduction under section 125.1 of the Income Tax Act (the “Act”). ...

2012 Ruling 2010-0355941R3- reverse subsidiary merger- 87(1) & 87(11) Unedited CRA Tags 87(1)(a) & 87(11)(b) Principal Issues: Whether the reverse subsidiary merger, as described below, will be considered an amalgamation in the context of subsection 87(11) within the meaning of that term in subsection 87(1) and whether, on the reverse subsidiary merger, a new corporation (Amalco) will be considered to have acquired each capital property of the subsidiary (Target) within the meaning of paragraph 87(11)(b)? ...

2018 Ruling 2017-0711071R3- Use of subsidiary losses & ITCs after wind-up Unedited CRA Tags Subsections 88(1) & (1.1) Principal Issues: Can losses and ITCs of a subsidiary be claimed by a parent on a winding-up as a result of a two-step loss acquisition where the loss business carried on by the subsidiary and the shares of the subsidiary are acquired in separate transactions. ...

24 August 1998 External T.I. 9805845- FARMERS & TIMBER Unedited CRA Tags 110.6(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Do they answers to 1 & 2 change if the property was transferred to the taxpayers son in 1985? ... All of the comments in 1 & 2 would apply to the son. 4. It depends. 5. ...

2008 Ruling 2008-0267631R3- income trust, stapled units & elimination of corp Unedited CRA Tags 132.2 Principal Issues: 1. ... GP Inc. is entitled to XXXXXXXXXX % and LP Inc. is entitled to XXXXXXXXXX % of the income or loss of the partnership, pro rata. ... Each note bears interest at a rate of XXXXXXXXXX % per annum payable XXXXXXXXXX, and is unsecured. 14. ...