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The relevant facts regarding the US Group's business carried on in the US as of, or in respect of, the US Group's financial years ending XXXXXXXXXX, are as follows: * XXXXXXXXXX. ...

Yours truly, XXXXXXXXXX For Director International Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

Pursuant to the Plan, the Interest on Notes A and Notes C is computed daily on the basis of the Bank of Canada average XXXXXXXXXX month BA rate, while the Interest on Notes B is computed daily on the basis of the Bank of Canada average XXXXXXXXXX month BA rate + XXXXXXXXXX%. 18. ...

Yours truly, XXXXXXXXXX For Director International Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

Reasons: (1) & (2) The lump sum payment is not considered a qualifying "support amount" for purposes of paragraphs 56(1)(b) and 60(b) of the Act. ...

Definitions In this letter, unless otherwise stated, the following terms have the meaning specified below: (a) "adjusted cost base" " has the meaning assigned to that term in section 54 of the Act; (b) "Business" means the business of XXXXXXXXXX located adjacent to the Properties; (c) "Canco" means XXXXXXXXXX; (d) "capital property" has the meaning assigned to that term in section 54 of the Act; (e) "controlled foreign affiliate" has the meaning assigned to that term in subsection 95(1) of the Act; (f) "Country X" means XXXXXXXXXX; (g) "CRA" means Canada Revenue Agency; (h) "designated liquidation and dissolution" has the meaning assigned to the term in subsection 95(1) of the Act; (i) "excluded property" has the meaning assigned to that term in subsection 95(1) of the Act; (j) "foreign accrual property income", also referred to herein as "FAPI", has the meaning assigned to that term in subsection 95(1) of the Act; (k) "foreign affiliate" has the meaning assigned to that term in subsection 95(1) of the Act; (l) "Foreign Corp" means XXXXXXXXXX; (m) "Foreign Holdco" means XXXXXXXXXX; (n) "Foreign LP" means XXXXXXXXXX; (o) "foreign resource property" has the meaning assigned to that term in subsection 66(15) of the Act; (p) "Foreign Subco1" means XXXXXXXXXX; (q) "Foreign Subco2" means XXXXXXXXXX; (r) "Foreign Subco3" means XXXXXXXXXX; (s) "Foreign Subco4" means XXXXXXXXXX; (t) "Mine 1" means XXXXXXXXXX located in XXXXXXXXXX; (u) "Mine 2" means XXXXXXXXXX located in XXXXXXXXXX; (v) XXXXXXXXXX; (w) "Parent" means XXXXXXXXXX; (x) "proceeds of disposition" has the meaning assigned to that term in section 54 of the Act; (y) "Properties" means Mine 1 and Mine 2, collectively; (z) "public corporation" has the meaning assigned to that term in subsection 89(1) of the Act; (aa) XXXXXXXXXX; (bb) XXXXXXXXXX; (cc) XXXXXXXXXX; (dd) XXXXXXXXXX; (ee) "taxable Canadian corporation" has the meaning assigned to that term in subsection 89(1) of the Act; and (ff) "US$" means United States dollars. ...

In the past, XXXXXXXXXX Holdco 2 has been used to directly or indirectly acquire XXXXXXXXXX % of the shares of selected active businesses operating outside of Canada and XXXXXXXXXX from arm’s length persons. ...

(d) "XXXXXXXXXX " is described in Paragraph 2. (e) "CRA" means the Canada Revenue Agency. ...

Yours truly, for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

The interest rate on the Limited Partnership Promissory Note will be the prime rate as statistically monitored by the Bank of Canada plus XXXXXXXXXX %. ...