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Pubco has direct ownership in the following subsidiary corporations in the following percentages: Subco (XXXXXXXXXX %) XXXXXXXXXX XXXXXXXXXX (This subsidiary provides services to other companies in the group.) ... On XXXXXXXXXX, Subco entered into a share purchase agreement with Pubco pursuant to which it purchased, from Pubco, XXXXXXXXXX shares in the capital of XXXXXXXXXX, representing XXXXXXXXXX % of the issued and outstanding shares of XXXXXXXXXX in consideration for the issuance of the Subco Shares. ... It is expected that XXXXXXXXXX will acquire XXXXXXXXXX % of Pubco’s interest in XXXXXXXXXX PURPOSE OF THE PROPOSED TRANSACTION 19. ...

Each of the Special A Shares will have a non-cumulative dividend entitlement of XXXXXXXXXX % per annum calculated on the Special A Shares Redemption Amount. ... Each of the Special C Shares will have a non-cumulative dividend entitlement of XXXXXXXXXX % per annum calculated on the Special C Shares Redemption Amount. ... The Special C Shares will have a non-cumulative dividend entitlement of XXXXXXXXXX % per annum calculated on the Special C Shares Redemption Amount. ...

Although the quantity of Reverse Repo Transactions involving debt obligations issued by Canadians will depend upon factors such as the availability of such debt obligations and the currency required by the Customers of Opco, the aggregate principal amount of such debt obligations acquired by Opco in Reverse Repo Transactions will at all times be less than XXXXXXXXXX % of the aggregate principal amount of Opco's total portfolio of debt obligations. However, it is possible that Opco's gross revenue in respect of Reverse Repo Transactions involving debt obligations issued by Canadian residents may exceed XXXXXXXXXX % of Opco's total gross revenue from Opco's entire portfolio of debt obligations. 10. ... Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

It is anticipated that the First Nation will have a XXXXXXXXXX % interest in the LP. 9. ... However, in the course of obtaining outside financing for its capital contribution, the First Nation will obtain a loan (the "Loan") from the Corporation (or an entity related to the Corporation, as the case may be) to a maximum of XXXXXXXXXX % of the First Nation's equity investment. ... The remaining XXXXXXXXXX % of capital required to be contributed by the First Nation to fund its equity interest in the LP, will be contributed by the Corporation on behalf of the First Nation. ...

At the time the Notes were issued, the exchange rate was US$1 = C$1.6107. ... The Notional Principal Amounts are to be exchanged on XXXXXXXXXX or, if the parties elect pursuant to the "Optional Early Termination Provisions" to terminate the Swaps on XXXXXXXXXX (the "Optional Early Termination Date"), on that earlier date. b) A Co has agreed to pay the Counterparties aggregate fixed payments at an annual rate of XXXXXXXXXX % of the C$ Notional Principal Amount and the Counterparties have agreed to pay A Co's aggregate fixed payments at an annual rate of XXXXXXXXXX% of the US$ Notional Principal Amount (the "Periodic Payments"). ... Assuming that the exchange rate used in the calculation is US$1 < C$1.6107, the calculation will assume that A Co would have been required under the Swaps to make aggregate net payments to the Counterparties in respect of the Notional Principal Amounts and the Periodic Amounts. ...

The material assets of OriginalCo are as follows: (a) all of the issued and outstanding common shares of CanSubco-2, which have an adjusted cost base to the holder and paid-up capital of $XXXXXXXXXX per share; (b) all of the issued and outstanding common shares of CanSubco-1, which have an adjusted cost base to the holder in paid up capital of $XXXXXXXXXX per share; (c) all of the issued and outstanding common shares of US Holdco; (d) all of the issued and outstanding preferred shares of US Subco-2; (e) XXXXXXXXXX % of the issued and outstanding common shares of Can Subco-3; (f) XXXXXXXXXX % of the Class A Units of Operating LP, XXXXXXXXXX % of the Class B Units of Operating LP and XXXXXXXXXX % of the Class C Units of Operating LP; (g) working capital, unit purchase loan plan receivable and intangible assets in connection with the Business; and (h) the Forward Transfer Agreement. 12. ... US Subco-2 has loaned $XXXXXXXXXX to US Subco-1 at an annual interest rate of XXXXXXXXXX %. ... XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Definitions The following definitions have been used in this letter: (a) “Agreement” refers to any AFA or AFP Agreement; (b) “AFA Agreement” or “AFA” refers to any agreement entered into by the Ministry, the Governance Organization and the Association, pursuant to which the Ministry provides funding for Professional Services and related activities; (c) “AFA Funds” refers to any funds received by the Partners directly or indirectly, from the Government of XXXXXXXXXX pursuant to the provisions of the AFA Agreement; (d) “AFP Agreement” or “AFP” refers to any the agreement entered into by the Ministry, the Governance Organization, and the Associations, pursuant to which the Ministry provides funding for various Professional Services, Non-Professional Services and related activities; (e) “AFP Funds” refers to any funds received by the Partners, directly or indirectly, from the Province pursuant to the provisions of the AFP Agreement; (f) “Associations” refers to “XXXXXXXXXX ” and “XXXXXXXXXX ”; (g) “CCPC” refers to a “Canadian-controlled private corporation” as defined under subsection 125(7) of the Act; (h) “XXXXXXXXXX AFA” refers to the AFA Agreement relating to the provision of XXXXXXXXXX Professional Services XXXXXXXXXX; (i) XXXXXXXXXX; (j) “College” refers to the College of Physicians and Surgeons of the Province; (k) “Contract” refers to the written sub-contracting agreement which will be used to set out the terms and conditions by which a ProCorp will provide Professional Services to the Partnership; (l) “CRA” refers to the Canada Revenue Agency; (m) “Department” refers to the XXXXXXXXXX of the Hospital; (n) “Electing Partner” refers to a Partner who elects to provide his or her Professional Services through a ProCorp; (o) “Fees” refer to the fair market value fee to be charged under the Contract by a ProCorp to the Partnership; (p) “Funds” refer to any funds received by the Partnership, directly or indirectly, from the Province pursuant to the provisions of an Agreement; (q) “General AFA” refers to the AFA Agreement relating to the provision of XXXXXXXXXX Professional Services XXXXXXXXXX; (r) XXXXXXXXXX; (s) “Governance Organization” refers to the XXXXXXXXXX; (t) “Hospital” refers to the XXXXXXXXXX; (u) “Income” refers to the Partnership’s income or loss for a particular Taxation Year as computed under subsection 96(1) of the Act; (v) “Member” refers to an individual physician who is a member of one of the Associations and who will become a Partner; (w) “Ministry” refers to the XXXXXXXXXX of the Province; (x) “Non-Electing Partner” refers to a Partner who does not elect to provide Professional Services through a ProCorp; (y) “Non-Professional Services” refer to any services provided by Partners on behalf of the Partnership, other than Professional Services, including the promotion of the Practice; (z) “Partner” refers to a partner of the Partnership as listed in Appendix A; (aa) “Partnership Agreement” refers to the partnership agreement by which the Partnership will be formed and governed; (bb) “Physician” refers to a member of the College who holds a certificate of registration to practice medicine as issued by the College; (cc) “Practice” encompasses both Professional Services and Non-Professional Services; (dd) “ProCorp” refers to any of the corporations to be formed by an Electing Partner and through which an Electing Partner will provide Professional Services as an employee of that corporation; (ee) “Professional Services” refers to patient care services and all direct and indirect services ancillary to the provision of patient care services as provided by the Partners through the Partnership; (ff) “Province” means the Province of XXXXXXXXXX; (gg) “Provincial Medical Association” refers to the XXXXXXXXXX; (hh) “Provincial Funds” refer to any funds received by the Partnership, directly or indirectly, from the Province pursuant to an Agreement; (ii) “Public Plan” refers to the XXXXXXXXXX Health Insurance Plan XXXXXXXXXX; (jj) “Related Persons” has the meaning assigned by subsection 251(2) of the Act; (kk) “TCC” refers to a “taxable Canadian corporation” as defined under subsection 89(1) of the Act; (ll) “Taxation Year” refers to the Partnership’s taxation year for income tax purposes which is defined in paragraph 96(1)(b) of the Act as the Partnership’s fiscal period; and (mm) “University” refers to the XXXXXXXXXX. ...

For greater certainty, the DSUs do not entitle a Participant to any shareholder rights vis-à-vis Aco, Bco or Cco, including – without limitation – voting rights, dividend entitlements, or rights on liquidation. 15. ...

Position Adoptée: Pourvu que les administrateurs de la Société, en plus de ne pouvoir généralement pas verser de dividendes, ne puissent autrement payer ou procurer de revenu ou d'avantages aux actionnaires pour leur bénéfice personnel, l'unité composée du bail et d'actions, indivisible en raison de l'effet combiné des statuts et règlements de Société et du bail en propriété exclusive et donnant à son détenteur le droit de jouir personnellement de l'unité d'habitation à laquelle elle se rattache se qualifiera au titre de logement pour les fins de la définition de " résidence principale " à l'article 54 de la Loi. ...

Reasons: See issue sheets of files # 2001-0114583 and # 2001-0089903. ...