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The recent dividend history of the common shares of Pubco is as follows: Fiscal Year Annual Dividends Per Share* XXXXXXXX XXXXXXXXXX XXXXXXX XXXXXXXXXX XXXXXXX XXXXXXXXXX XXXXXXX XXXXXXXXXX XXXXXXX XXXXXXXXXX XXXXXXX XXXXXXXXXX XXXXXXX XXXXXXXXXX * restated to reflect a stock dividend paid XXXXXXXXXX 4. ...

Definitions and Abbreviations In this letter, the following terms have the meanings specified: (a) "Act" means: the Income Tax Act, R.S.C. 1985 (5th Supp.) c.1, as amended to the date hereof; (b) "CCRA" means: the Canada Customs and Revenue Agency; (c) "Corporation " means: XXXXXXXXXX; (d) "Corporation A" means XXXXXXXXXX, which is a taxable Canadian corporation for purposes of the Act; (e) "Corporation B" means XXXXXXXXXX, the U.S. parent of Corporation A; (f) "Employee" means: XXXXXXXXXX; (g)"Options" means the outstanding options issued to the employee by Corporation B in accordance with the terms of the Plan; (h) "Plan" means: means the XXXXXXXXXX; (i) "Regulations" means: The Income Tax Regulations; and (j) "Share" means: means a common share of Corporation B. ...

The ownership of share capital and XXXXXXXXXX debt of the Company as at XXXXXXXXXX is summarized as follows (the group collectively is referred to herein as "the Shareholders" and any of the following is referred to herein as a "Shareholder"): Shareholder # of Shares XXXXXXXXXX Debt XXXXXXXXXX The Shareholders of the Company are not related to any other Shareholder within the meaning of "related persons" provided in subsection 251(2) of the Act. 5. ...

Principal Issues: Whether a reduction in mgt fees for some unitholders causes 104(7.1) to deny a deduction under 104(6) and whether the proposed changes cause the funds to lose their status as unit trusts Position: 1: No 2: No Reasons: See previous rulings 941353, 942514 & opinion 901041 XXXXXXXXXX XXXXXXXXXX 991267 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 1999 Dear Sirs: Re: XXXXXXXXXX Advance Income Tax Ruling We are writing in reply to your letter of XXXXXXXXXX, in which you requested an advance income tax ruling on behalf of the above-noted trust and beneficiaries under the trust in respect of the income tax consequences arising out of the proposed transactions described below. ...

Principal Issues: Where an income distribution reinvestment plan of a unit trust enables a unitholder to reinvest income distributions in new units at a price equal to XXXXXXXXXX % of the average market price and without commission or service charge, will a benefit be considered to be conferred pursuant to subsection 105(1)? ...

Yours truly, for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

It is anticipated that XXXXXXXXXX other First Nations located in XXXXXXXXXX will become limited partners of LP1 and will each acquire a XXXXXXXXXX % interest in the partnership. ...

To the best of your knowledge, and that of the taxpayer involved, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayer or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or a related person; (iii) under objection by the taxpayer or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...

Immediately after the Shares are issued under the proposed transaction, Annuitants will own (and will be deemed to own by virtue of the definition of "specified shareholder" in subsection 248(1), paragraphs (a) and (b)) Shares as follows: RRSP Shareholders Fraction of Share Owned % Company Owned XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX PURPOSE OF THE PROPOSED TRANSACTION 13. ...

In this letter, the following terms have the meanings specified: (a) "Act" means the Income Tax Act, R.S.C 1985 (5th Supp.) c.1, as amended to the date hereof, and, unless otherwise stated, every reference herein to a Part, section, subsection, paragraph or subparagraph is a reference to the relevant provision of the Act; (b) "Canadian resource property" has the meaning assigned by subsection 66(15); (c) "CCOGPE" means "cumulative Canadian oil and gas property expense" within the meaning assigned by subsection 66.4(5); (d) "COGPE" means "Canadian oil and gas property expense" within the meaning assigned by subsection 66.4(5); (e) "GOR agreement " means the agreement described in paragraphs 5, 6 and 7 below between Petroleum Co. and the resource company, and which will be substantially similar to the Royalty Agreement dated XXXXXXXXXX that was provided with your advance income tax ruling request; (f) "Grantor of the GOR agreement" is the resource company that is party to the GOR agreement with Petroleum Co.; and (g) "Petroleum Co. ...