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Beginning with the first dividend in the sixth year, the dividend is determined using one of three methods undertaken in the following order: 1) Investor negotiation procedure • direct negotiation between the company and the shareholders if that doesn't work... 2) Dealer bid procedure • obtain bids from Investment Dealers • each bid will specify (1) a fixed or floating dividend rate (2) the fee to be paid to the Dealer if its bid is selected (3) the length of the period to be in force • any such bid is an unconditional offer by the Dealer to purchase all shares tendered by holders • company selects a winner, notifies the shareholders of the dividend rate and the dealer name • shareholders not satisfied with the terms can request that the dealer purchase all or a portion of their shares if a bid isn't selected by the company or none is submitted... 3) Auction procedure • the dividend rate for each quarter is based on orders placed in an auction conducted prior to the commencement of each quarter • the rate established by auction (the "Established Rate") will be applicable for the next quarter • the maximum rate allowed may be capped, at say Bankers' Acceptance Rate plus 50 basis points or 110% the "AA" Composite Commercial Paper Rate • existing holders submit any of the following orders: (1) "Hold order"- hold without regard to the Established Rate set by auction (2) "Bid order"- specify number to hold provided that the Established Rate for the next quarter is not less than a specified rate (3) "Sell order" sell without regard to the Established Rate set by auction • if no order is received, a holder is deemed to have submitted a hold order • individuals interested in acquiring shares may submit "bid to buy orders" with the condition that the Established Rate is not less than a rate specified by the potential holder. • bid to buy orders can come from existing holders as well as new investors • sell and bid orders are irrevocable • if all existing shareholders give hold orders, the next quarter's dividend rate is set, at say 50% of Prime Rate (this clause exists to help ensure that the auction procedure works) The auction procedure works as follows: 1)- the established rate will be the lowest rate that clears the market by matching sales and purchases 2)- a maximum rate is set ("ceiling rate") 3)- existing Holders submit hold, bid, bid to buy and sell orders 4)- potential Holders submit bid to buy orders 5)- determine number of shares available for sale which equals total outstanding less hold orders • if none, established rate set at 50% of Prime Rate 6)- determine whether the number of bid to buy orders with dividend rates less that the ceiling rate, which does not include bid orders, is equal to or exceeds the number of shares offered to be sold regardless of dividend rate plus the number of bid orders by existing holders at rates higher than the ceiling rate • if yes, sufficient clearing bids exists- if no, considered a failed auction Sufficient Clearing 7)- the Established Rate is the lowest rate specified in the submitted bid orders which, taking into account such rate and all lower rates bid by Existing Holders and Potential Holders, would result in such Existing Holders and Potential Holders owning all available shares 8)- each Existing Holder with a submitted bid order specifying a rate higher than the Established Rate or that offered to sell shares without regard to the rate shall sell their shares 9)- each Existing Holder with a submitted bid order specifying a rate lower than the Established Rate-shall continue to hold their shares 10)- each Potential Holder with a submitted bid to buy order specifying any rate that is lover than the Established Rate will buy the number of shares so submitted 11)- each Existing Holder with a submitted bid order specifying a rate equal to the Established Rate shall continue to hold their shares unless the number of shares subject to all such submitted bids is greater than the shares available determined in (5) less the number already already allocated in (9) and (10) ("Remaining shares"), in which case each Existing Holder with such a submitted bid shall sell a number of shares determined on a pro-rata basis: Remaining shares x Bidder's shares involved in tie-------------------------- All shares involved in tie • no pro-rations were required prior to this point due to the condition imposed in (6) above. 12)- each potential holder with a bid to buy order specifying a rate equal to the Established Rate shall purchase any available shares not accounted for in (9), (10), and (11) above on a pro-rata basis: Available shares less (9),(10),(11) x Individual's request to bid to buy---------------------------------- Total # of shares still subject to bid to buy • the operation of an auction is illustrated in attached example 1. ... Available Shares 100- # subject to firm hold = 100- 0 = 100 As the number of bid orders by Potential Holders specifying rates equal to or lower than the ceiling rate 20 shares bid by bidder #6 is less than the number offered to be sold by Existing Holders regardless of the dividend rate plus the number bid by Existing Holders at rates higher than the ceiling rate: 10 shares offered to be sold by Bidder #1 20 shares offered to be sold by Bidder #2 30 shares bid for by Bidder 04 at a rate above the ceiling rate 60 sufficient clearing bids do not existing. ... Acceptance and Rejection of Bids, Bids to Buy end Sells 1) Existing Holders with bid rates equal to or lower than 11%, continue to hold Bidder #3 holds 30 shares Bidder #5 holds 10 shares 2) Potential Holders with bid rates equal to or lower than 11%, purchase Bidder #6 purchases 20 shares 3) Existing Holders with bid rates higher than 11% or that offered to sell without regard to the Established Rate, sell a pro-rata number to meet demand Bidder #1 wants to sell 10 shares Bidder #2 wants to sell 20 shares Bidder #4 wants to sell 30 shares but only 20 shares need to be sold Each sells a proportionate number: Bidder #1 sells 10 x 20 = 3 60 Bidder #2 sells 20 x 20 = 7 60 Bidder #3 sells 30 x 20 = 10 60 After settlement, shareholdings are as follows: Bidder #1 holds 7 Bidder #2 holds 13 Bidder #3 holds 30 Bidder #4 holds 20 Bidder #5 holds 10 Bidder #6 holds 20 100 Each will receive a dividend of 11.000% for the next quarter. ...

In your letter and the attached document you describe financing arrangements for the plan to include: * Annual increases in monthly salary, * Cash performance bonus awards, or * Bonus awards in the form of stock exchangeable for cash. ...

c) Un individu possède la totalité des actions en circulation de Opco dont le prix de base rajusté est de 100 000 $, le capital versé de 500 000 $ et la juste valeur marchande de 600 000 $. ... La somme convenue entre l'individu et Opco dans leur choix en vertu de l'article 85 de la Loi est de 500 000 $. i) L'individu est-il réputé avoir reçu un dividende de 100 000 $ en vertu du paragraphe 84(1) de la Loi en considérant que le paragraphe 85(2.1) de la Loi réduit le capital versé des actions émises à titre de contrepartie d'un montant de 100 000 $? ... Le capital versé à l'égard des nouvelles actions sera donc également réduit en vertu du paragraphe 85(2.1) d'un montant de 100 000 $ et sera par conséquent égal à 500 000 $. ...

Example Plant sales revenue $100,000 (processed gas) Plant expenses, excluding notional cost of raw gas 30,000 Return on investment in the plant ("ROI") 12,500 Production costs 20,000 Using these figures the estimated value of raw gas is: Sales $100,000 less Plant expenses $30,000 ROI- plant 12,500 42,500 Estimated value of all produced raw gas 57,500 Production revenue would be: Value of produced raw gas $ 57,500 less Production costs 20,000 Production revenue 37,500 A separate accounting for produced raw gas which is consumed in processing would result in the same production revenue figure, as shown below: Estimated value of raw gas Sales $100,000 less Plant expenses $30,000 ROI- plant 12,500 Value of raw gas consumed X 42,500 + X Value of produced raw gas sold $ 57,500- X The value of all produced raw gas would be the total of the value of produced raw gas sold (i.e., $57,500- X) plus the value of produced raw gas consumed (i.e., X). The sum of these amounts is (57,500- X) + X = $57,500. Production revenue under this approach is therefore $57,500- 20,000 = $37,500, the same figure as was determined using the first method above. ... Yours truly, Chief Mines, Oil & Forest Industries Section Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch ...

The Day & Ross case was relied upon in the TNT decision which the 24(1) claims is identical to its situation. 3. ... Alex Von Glehn & Co. Ltd., 12 T.C. 232. In Day & Ross, Dube, J. seemed to take a more liberal view of the deductibility of fines under paragraph 18(1)(a) of the Act. " and at p.101 "... we have seen a more liberal approach to the subject in Day & Ross and more likely will follow. ...

6 December 1990 Income Tax Severed Letter F 24(1) 5-903062 André Payette (613) 957-8953 19(1) Le 6 décembre 1990 Monsieur, OBJET: Allocation de retraite La présente est en réponse à votre lettre du 17 octobre 1990 dans laquelle vous demandiez notre interprétation quant à la situation hypothétique suivante: * Un employé, ayant travaillé pendant 20 ans au sein d'une corporation avec qui il n'a pas de lien de dépendance, prend sa retraite; * Son salaire moyen au cours des 5 dernières années est de 75,000 $; * Au cours de ces cinq dernières années, suivant les calculs effectués par un actuaire, la corporation a versé dans un fonds de pension enregistré pour cet employé, pour services passés et services courants, des contributions totalisant 200,000 $; * L'employé envisage maintenant de prendre sa retraite et la corporation est consentante à lui verser une allocation de retraite de 100,000 $. ...

HYPOTHETICAL SITUATIONS: Case #1:-     A Canadian resident company wants to solve a specific engineering problem in Canada.-     Since the Canadian company does not have the required expertise to solve the said problem, it retains the services of a non-resident engineer having the required expertise.-     The services of the engineer are rendered outside of Canada.-     The engineer comes up with a solution.-     The fees charged for the engineering work are at an hourly rate of $125.00 (the $125 can be split as follows: engineer's salary $75; mark-up $50). Case #2-     A Canadian company entered into a service contract with a non-resident engineering company.-     The contract provides for technical assistance which will be rendered outside Canada.-     The information derived from the technical assistance is used in Canada.-     A portion of the costs is allocated to technical assistance services. Case #3-     A non-resident engineering company has an extensive research program.-     The conclusion of its research are put together in a training course offered to engineers resident in Canada.-     The training course is given outside Canada.-     The registration fees are of a specific amount.-     The technical information derived from the training courses will be used in Canada. ...

JURIDIQUE: n/a OPINION DE FINANCE: n/a JURISPRUDENCE: n/a PUBLICATIONS DE REVENU CANADA IMPÔT: n/a DOSSIER SUJET: HAA 1250 — 4 (Congrès APFF) HAA 5638 — 3 (Partie I.3) Table Ronde de l'APFF — Colloque "la taxe sur le capital" le 16 novembre 1993 Question 15. ...

While not defined in the Act, the term "health and welfare trust" is used in Interpretation Bulletin IT-85R2 "Health and Welfare Trusts" (copy attached) to describe a trust which has been set up exclusively to provide employees with one or more of the following benefits:-     group sickness or accident insurance plan,-     a private health services plan and-     a group term life insurance policy. ...

• housing for expatriate employee and family • schooling/education costs to provide English language (or equivalent) schooling for dependent children • fees paid to a property management firm to care for the employee's residence in Canada while on assignment • financial counselling relevant to assignment • tax return preparation relevant to assignment- both Canadian and foreign tax returns • expenses related to home leave (for example- return air fare for expatriate employee and family- once per year to return to Canada- or equivalent destination) • transportation to and from work. ... • payment of goods and services differential- this amount would equate to $x per month, based on certain economic indicators and compensates an employee for the differences in purchasing power between Canada and the expatriate location (ie. inflation protection). • payment of hardship allowances that compensate the employee for extraordinary working and living conditions in the foreign county. • payment of a relocation allowance • reimbursement of moving expenses DEPARTMENT'S POSITION A determination of the employees Canadian residence status while abroad must be made (see our comments in Question #2). ... In addition, this would not be a taxable benefit to the employee if employer considered to be providing free or subsidized school services in a remote or unorganized area (8(1)(b); IT470R, par. 31); • Property Management Fees- Taxable (6(1)(b)); • Financial Counselling- Taxable (6(1)(b) IT-470R S.R. par.8); • Tax Return Preparation- Taxable (8(1)(b) IT-470R S.R. par.8) • Expenses Related to Home Leave- Taxable (6(1)(b)); • Transportation To/From Work- Normally taxable (6(1)(b)). ...