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In the third bullet in paragraph 36, insert the following words between the words "that" and "during" in the fourth line: ", commencing on the earlier of the date of repayment of the Purchase Note described in paragraph 32 above or XXXXXXXXXX," Notwithstanding the above change, we confirm that the Ruling will continue to be binding on the Canada Customs and Revenue Agency in the manner described therein, provided the offering by the Offering Partnership of its Class A Units is completed on or before XXXXXXXXXX. ...

& 3. The position described in paragraph 27 of IT-470R (Consolidated) would not apply to gas allowances and rebates paid directly to employees. ...

Reasons: 1) We have never seen a plan that calls for the payment of total salary based on a percentage of profits being paid to an EPSP. 2) The formula under 144(1) states that the % of profits has to be paid to the EPSP; however, more flexibility with "out of profits" formula. 3) The provisions of section 144 allow the employer to restrict participation in an EPSP. ...

Yours sincerely, Bill McCloskey Assistant Deputy Minister Policy & Legislation Branch B. ...

Subsection 6(23) of the Act reads as follows: “Employer-provided housing subsidies — For greater certainty, an amount paid or the value of assistance provided by any person in respect of, in the course of or because of, an individual's office or employment in respect of the cost of, the financing of, the use of or the right to use, a residence is, for the purposes of this section, a benefit received by the individual because of the office or employment.” ...

La présomption prévue au paragraphe 15 du Bulletin est restreinte aux situations où l'employé ou le cadre transige sur des titres promus ou souscrits à forfait par son employeur: 15. (...) ...

The Technical Explanation to the Convention clearly indicates that the "... taxes not generally covered by the Convention include, in the case of United States, the estate... taxes... ...

Day (613) 957-2136 19(1) January 15, 1992 Dear 19(1) Re: Subsection 74.1(2) of the Income Tax Act (the Act) We are writing in reply to your letter of November 11, 1991, wherein you requested our opinion regarding the phrase "... from property or from property substituted" in the subject provision as it relates to the attribution of income on property transferred to a minor where a capital gain has resulted from the subsequent disposition of that property. ...

Les Delorme Business & General Chief of Audit Division Saskatoon D.O. ...

28 April 1992 Income Tax Severed Letter 9211150- Reasonableness of a Retiring Allowance PRAIRIE TAX CONFERENCE May 19 & 20, 1992 DRAFT/EBAUCHE Question 10 For a payment to be considered a retiring allowance and a deductible expense to the payer, the amount of the payment must be reasonable having regard to the length of service involved, its relationship to the remuneration received for the years of service and the value of other retirement benefits to which the employee is entitled. ...