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The Corporation will establish the "XXXXXXXXXX " (the "Plan") for the benefit of its resident and non-resident directors. ...

1999 Ruling 9831593- DIVISIVE REORGANIZATION Unedited CRA Tags 55(3)(a) 251(3) 251(6)(a) & (b) 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. ...

Any reductions of Shares acquired through the Plan will have to be approved by the Chairman & CEO of the Company, subject to the requirements of subparagraphs 4(j), (m) and (n) above. ...

All payments under the forward contracts will be linked to the investment returns of the appropriate Underlying Fund and will be governed by the following terms: (a) each Fund will pay transaction costs to the Counterparty as required under the forward contract which are initially anticipated to approximate the Counterparty's bankers' acceptance rate plus approximately XXXXXXXXXX % of the nominal value of the forward contracts; (b) if the net asset value of the Underlying Fund increases, the Counterparty will pay the Fund an amount equal to the increase in the exposure under the forward contracts; and (c) if the net asset value of the Underlying Fund decreases, the Fund will pay the Counterparty an amount equal to the decrease in the exposure under the forward contract. 10. ...

XXXXXXXXXX 2021-087667 XXXXXXXXXX, 2021 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request – Transfer between U.S. pension plans XXXXXXXXXX This is in reply to XXXXXXXXXX email of XXXXXXXXXX requesting that we resume our consideration of the request for an advance income tax ruling (“Ruling”) on behalf of the XXXXXXXXXX that was originally submitted in XXXXXXXXXX letter of XXXXXXXXXX. ...

The Fund directly holds all of the outstanding units and notes of XXXXXXXXXX Trust, and indirectly holds limited partnership units of XXXXXXXXXX LP (representing approximately XXXXXXXXXX % of the outstanding limited partnership units of XXXXXXXXXX LP), all of the shares of GP Co (the sole trustee of the Trust, being the general partner of XXXXXXXXXX LP and Holdings LP), and all of the shares of Beneficiary, the sole beneficiary of the Trust. 3. ... However, advances evidenced by the Sub-Loan Note will bear interest at a rate of XXXXXXXXXX % per annum in excess of the interest rates under the New Credit Facility. 30. ...

Partnership will assume the O & M Agreement such that the XXXXXXXXXX Assets will be operated in substantially the same manner a before their transfer to Partnership. 18. ... It is not anticipated that any prospective Debenture Holder will hold more than XXXXXXXXXX % of the units of Income Fund. ...

XXXXXXXXXX prior ruling (file # 972815) re: identical transaction (transaction was not completed). 2. ... On the Redemption Date, ACO will be required to make a cash payment equal to the Redemption Price to those Holders who surrender their Units for redemption. g) If a Fundamental Change of Control (as defined below) of BCO occurs, each Holder will have the right, at the Holder's option, to require ACO to purchase all or any part of the Holder's Units on the date (the "Repurchase Date") that is XXXXXXXXXX days after the date ACO gives notice of the Fundamental Change of Control at a price (the "Repurchase Price") equal to XXXXXXXXXX % of their Principal Amount plus accrued Interest to the Repurchase Date, after which the related Warrants will automatically expire. ...

Note " means the interest-bearing promissory note in the principal amount of USD$XXXXXXXXXX issued by ULC to U.S. ... Yours truly, XXXXXXXXXX Section Manager For Division Director International Section I Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

On XXXXXXXXXX, Eco used part of its excess funds to make an interest free loan of $ XXXXXXXXXX to Cco (the “Cco Loan”). 20. On XXXXXXXXXX, Cco, with the proceeds from the Cco Loan, made an interest free loan of $ XXXXXXXXXX to Aco (the “Aco Loan 2”). ...