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Any investor or group of investors that holds at least XXXXXXXXXX % of the units of the REIT will be entitled to appoint a member to the Board of Trustees of the REIT. ... Yours truly, XXXXXXXXXX Section Manager For Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

& B Yes C&D. No Reasons: A.. Substantially the same issues as in past ruling 2002-018047. ... XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Pursuant to the Minutes of Settlement, the Parties will apply to the Court to have the Will and the Trusts created under the Will varied in the following manner: (a) Codicil A and its subsequent revocation will be ignored; andXXXXXXXXXX; (b) the Estate will be administered as if the residue clause in paragraph XXXXXXXXXX of the Will remained in effect as originally set out in the Will, subject to the variation set out below: (i) with respect to the residue of the Estate described in paragraph XXXXXXXXXX of the Will, the Children will be entitled to XXXXXXXXXX% of the residue such that each Child receives one-third of that amount, and XXXXXXXXXX % of the residue will be settled on the Trusts such that Trust1, Trust2 and Trust3 each receive one-third of that amount; (ii.1) the Children will not be entitled to any of the income or capital of any of Trust1, Trust2 or Trust3; (ii) references to the vesting of a Grandchild's share of the Estate described in paragraph 5(a) and (c) above will be changed from age XXXXXXXXXX to age XXXXXXXXXX; (iii) subparagraph XXXXXXXXXX of the Will will be amended to provide that payments of income and capital for the benefit of a Grandchild will continue to be discretionary beyond age XXXXXXXXXX until the capital is distributed at age XXXXXXXXXX and that the Trustees are directed to take into account any other resources which the Trustees reasonably believe are, or should be, available to such Grandchild, including the means of his or her parents or guardians when considering making distributions to a Grandchild; and (iv) the provision governing distribution of a Grandchild's share if he or she dies before the age of XXXXXXXXXX will be changed to delete members of his or her parent's generation as potential recipients of that Grandchild's share in the event that the Grandchild dies without issue before the final distribution from the Trust. 14. ... XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

(j) "DC Common Shares " means the voting common shares of DC described in 2 below. ... Yours truly, Director Financial Industries Division Income Tax Rulings Directorate Policy & Planning Branch ...

2091 Ruling 91268930- QSBC SHARES PURIFICATION Unedited CRA Tags 55(3)(A) 110.6(1) 69(1)(B) & (C) 85(1) XXXXXXXXXX 3-912689 Attention: XXXXXXXXXX Dear Sirs: Re: XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX We are writing in response to your letter of XXXXXXXXXX in which you requested an advance income tax ruling on behalf of the above-noted taxpayers in respect of the proposed transactions described below. ... XXXXXXXXXX Class B preferred shares, non-voting, of no par value, having a non-cumulative dividend rate not exceeding XXXXXXXXXX %, redeemable and retractable at an amount equal to the fair market value of the consideration for which they are issued, and issuable as Series 1 and Series 2. 14. ...

No person in whom there is an interest that is a " tax shelter investment" may subscribe for Units of the Partnership. ... (e) The Limited Partners will have the right, but not the obligation (the " Put" Right"), to require Parentco to purchase all, but not less than all of the Units for consideration equal to the fair market value of the Units at the time the Put Right is exercised, as determined by an independent valuator (selected by Parentco and the Limited Partners) using such valuation methods as are appropriate. ...

The authorized share capital of XXXXXXXXXX will consist of: (a) an unlimited number of Class A voting common shares which entitle the holder to have one vote per share at all meetings of the shareholders; (b) an unlimited number of Class B non-voting common shares; and (c) an unlimited number of Class C preferred shares and Class D preferred shares, each having the following attributes: (i) redeemable and retractable for a specified amount equal to the fair market value of the property for which the shares are issued (net of liabilities assumed by the corporation); (ii) the Class C preferred shares are entitled to a non-cumulative dividend at the fixed rate of XXXXXXXXXX % per annum (or such greater amount as may be set by the directors from time to time, not to exceed a reasonable amount) of the redemption amount and the Class D preferred shares are entitled to a non-cumulative dividend at the fixed rate of XXXXXXXXXX % per annum of the redemption amount; (iii) entitled to a prior return of the redemption amount on a liquidation, dissolution, or winding-up of the corporation; (iv) may be purchased, redeemed or cancelled by the corporation in the manner provided in the XXXXXXXXXX at the option of either the corporation or the holder for a price not less than the lesser of: (A) the aggregate redemption amount of such shares to be purchased at the particular time; and (B) the realizable value of the net assets of the corporation immediately before such purchase; (v) provide that any preference, right, condition or limitation attaching to the preferred shares can only be amended by a special resolution of the holders of each class of shares of the corporation each voting separately as a class; (vi) restrict the payment of dividends on other classes of shares so that no such dividends may be paid on any other class of shares of the corporation so as to reduce the value of the preferred shares then outstanding; and (vii) the holders of the Class C preferred shares will be entitled to one vote per share at all meetings of the shareholders. ...

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. ... The issued and outstanding shares of each class of shares of Investco are owned as follows: Shareholder # of Shares Class The Trust XXXXXXXXXX Class A Preferred XXXXXXXXXX Class B Preferred A XXXXXXXXXX Common XXXXXXXXXX Class A Preferred XXXXXXXXXX Class C Preferred B XXXXXXXXXX Common XXXXXXXXXX Class A Preferred XXXXXXXXXX Class C Preferred C XXXXXXXXXX Common XXXXXXXXXX Class A Preferred XXXXXXXXXX Class C Preferred 8. ...

The v-day value and the amount to retire each XXXXXXXXXX is as follows: Cdn $ XXXXXXXXXX V-day values XXXXXXXXXX XXXXXXXXXX Retirement amount (estimated) XXXXXXXXXX XXXXXXXXXX The retirement amount of the XXXXXXXXXX will not be less than the fair market value, on valuation day, of the XXXXXXXXXX issued. 33. ... The v-day value and the amount to retire each XXXXXXXXXX is as follows: Cdn $ XXXXXXXXXX V-day values XXXXXXXXXX XXXXXXXXXX Retirement amount (estimated) XXXXXXXXXX XXXXXXXXXX The retirement amount of the XXXXXXXXXX will not be less than the fair market value, on valuation day, of the XXXXXXXXXX issued. 35. ...

If Shares rank at the XXXXXXXXXX percentile (i.e. compared to all corporations in the XXXXXXXXXX), the Eligible Employee will be paid an amount equal to XXXXXXXXXX % of the target cash award set by the Committee in respect of that Performance Period. At the XXXXXXXXXX percentile rank, the Eligible Employee will be paid an amount equal to XXXXXXXXXX % of the target cash award set by the Committee and at or above the XXXXXXXXXX percentile rank, the Eligible Employee will be paid an amount (i.e. the maximum) equal to XXXXXXXXXX% of the target cash award set by the Committee in respect of that Performance Period. ...