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Y will be equal to or approximate the amount determined by the formula (A x B/C) + D as found in subparagraph (b)(iii) of the definition of "permitted exchange" in subsection 55(1). ...

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

Bco owns XXXXXXXXXX % of the shares of a LLC formed in the U.S. which, in turn, owns shares of three LCCs, which own directly properties located in the U.S.. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayers 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 taxpayers or a related person; (iii) under objection by the taxpayers 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. ...

The paid-up capital for income tax purposes is at least $ XXXXXXXXXX. ...

The Taxpayer is a taxable Canadian-controlled private corporation, XXXXXXXXX % of the shares of which are owned by an individual, XXXXXXXXX. ...

Upon the amalgamation of XXXXXXXXXX, as described in paragraph 13 above: (i) by virtue of subsection 87(1.1), the provisions of subsection 87(1) will apply; (ii) the provisions of paragraph 87(2)(a) will apply such that New XXXXXXXXXX will be deemed to be a new corporation the first taxation year of which will commence at the time of the amalgamation and XXXXXXXXXX will be deemed to have a taxation year end immediately before the amalgamation; (iii) the provisions of paragraph 87(2)(d) will apply in determining the capital cost and UCC to New XXXXXXXXXX of depreciable property; (iv) by virtue of paragraph 1102(14)(d) of the Regulations, depreciable property of a prescribed class of a predecessor corporation that is acquired by New XXXXXXXXXX upon the amalgamation will be deemed to be property of the same prescribed class to New XXXXXXXXXX; (v) in respect of each depreciable property acquired by New XXXXXXXXXX in respect of which the conditions described in Regulation 1100(2.2)(g) are met, the following rules will apply: (a) no amount will be included under Regulation 1100(2)(a) in respect of the property; and (b) each Class 24, Class 27, Class 29 and Class 34 asset will be deemed to be a "designated property " of the respective prescribed class to New XXXXXXXXXX for the purposes of Regulation 1100(1)(ta); and (vi) New XXXXXXXXXX will be entitled to deduct, pursuant to paragraph 20(1)(a), such CCA as is allowed by the Regulations, in computing income for its first taxation year. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayers 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 taxpayers or a related person; (iii) under objection by the taxpayers 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 judgement has been issued, the time limit for appeal to a higher court has not expired. ...

To the best of your knowledge, and that of the taxpayers involved, other than specifically disclosed in your letter of XXXXXXXXXX, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayers 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 taxpayers or a related person; (iii) under objection by the taxpayers 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. ...

The terms and conditions of the BCO Loan are as follows: a) The BCO Loan will be repayable in cash or in kind upon demand. b) Interest, at the Applicable Rate, will accrue daily on the outstanding principal amount and be payable periodically on each Payment Date. c) "Payment Date" is defined as XXXXXXXXXX. d) "Quarter " is defined as any 3 consecutive months ending on a Payment Date. e) The "Applicable Rate" of interest for any Quarter is equal to the Applicable Rate of Interest on the Loan plus 10 basis points. f) The first payment date will be XXXXXXXXXX. 8. ...