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Attachment General Formula Rate for a Team A = General Formula Rate for a Team B Where “A” represents the number of days that a regular member of the team is expected to be present in Canada during the team’s regular season (including pre-season). ...

Yours truly, for Director Reorganizations and Foreign Division Rulings Directorate Legislative and Intergovernmental Affairs Branch ANGIND E DOCNUM 9401365 REPLACES TYPEKEY R AUTHORDV LEGS AUTHOR CCHOUI DESCKEY 5 RATEKEY 1 REFDATE 940722 ETADYEAR ETADSORT ADMINACC LEGS ACCESSLV LEGS99 SUBJECT Non-qualifying real property SECTION ITA-110.6(1) SECTION SECTION SECTION SECTION $$$$ 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. ...

LAW: An "employee benefit plan" is defined in subsection 248(1) and the words which are relevant to the Plan described above are as follows: An arrangement under which contributions are made by an employer... to another person with whom the employer does not deal at arm's length (... the "custodian" of an employee benefit plan) and under which one or more payments are to be made to or for the benefit of employees or former employees of the employer or persons who do not deal at arm's length with any such employee or former employee. ...

The reference to "Supplemental Plan is implemented by XXXXXXXXXX " in the last paragraph is hereby deleted and replaced by "proposed transactions are completed by XXXXXXXXXX". ...

" 7. Paragraph 36 will be amended to read as follows: Oco will redeem all of its Oco XXXXXXXXXX Shares held by Cco for an amount equal to their fair market value, being the Oco XXXXXXXXXX Aggregate Redemption Amount. ...

A "qualifying amount" received by an individual in a taxation year means, inter alia, "...an amount (other than the portion of the amount that can reasonably be considered to be received as, on account of, in lieu of payment of or in satisfaction of, interest) that is included in computing the individual's income for the year and is (a) an amount (i) that is received pursuant to an order or judgment of a competent tribunal, an arbitration award or a contract by which the payor and the individual terminate a legal proceeding, and (ii) that is (A) included in computing the individual's income from an office or employment, or (B) received as, on account of, in lieu of payment of or in satisfaction of, damages in respect of the individual's loss of an office or employment, [...]." ...

The question and answer was reviewed by John Kurrant, Oil & Gas Specialist on June 12 and he said that he does not have any concerns. ...

The maximum CCA which Corporation AC may claim in respect of its 1988 taxation year is computed per paragraph 1100(l)(ta) of the Regulations as follows: An amount not exceeding the aggregate of: i) the aggregate of A) the lesser of Subtotals Totals i) 50% of the capital cost of designated property acquired in the year (50% of XXX) ii) UCC in respect of designated property acquired by virtue of specified transaction B) 25% of the lesser of I) UCC not including designated property acquired during the year II) capital cost of non-designated property acquired during the year Subtotals ii) the lesser of A) excess of UCC over capital cost of all property acquired in the year NIL B) an amount equal to the aggregate of I) 50% of capital cost of property acquired in preceding years NIL II) excess from clause A over amounts related to prior years NIL NIL NIL Available CCA as at June 30, 1988 for Corporation AC $86,562.50 ========== These comments represent our opinion of the law as it applies generally. ...

" Le terme "taxes'" est définie aux fins de l'application du paragraphe 23(2) de la Loi sur la gestion des finances publiques au paragraphe 23(1) de cette même loi 23. (1) Les définitions qui suivent s'appliquent au présent article. (...) ...

At the lower court level it was found that to constitute an amount receivable "... it was not enough to have a precarious right to receive the amount in question, but he must have a clear legal, though not necessarily immediate, right to receive it". ...