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The total purchase price of the Purchased Assets was allocated as follows: Land $ XXXXXXXXXX Land Improvements XXXXXXXXXX Buildings XXXXXXXXXX XXXXXXXXXX Equipment and Machinery XXXXXXXXXX $XXXXXXXXXX The Trust funded the purchase of the Purchased Assets by issuing interest bearing Notes to various public financial institutions and by issuing Trust Certificates to XXXXXXXXXX. ...

Cathie Figueira Section Acting Assistant Director Peter Lee Verification & Enforcement (613) 957-8977 Attention: Ms. ...

Corporations owned by Child 1 and Child 2 will become beneficiaries of the Family Trust in case Child 1 or Child 2 is a non-resident at the time a distribution would otherwise have been made to that child and which would have been subject to the proposed rule in the Notice of Ways & Means Motion of October 2, 1996 to the effect that property so distributed is deemed to have been disposed of at fair market value. ...

. * As defined in draft section 143.2. The opinions expressed above are provided in accordance with paragraph 22 of Information Circular 70-6R2. ...

July 17, 1997 Calgary Tax Services Office Resource Industries Graham Hoard Section Acting Assistant Director Peter Lee Verification & Enforcement (613) 957-8977 Attention: Doug Reeh Large File Case Manager 7-970054 XXXXXXXXXX Terminal Loss and Resource Allowance This is in reply to your memorandum of January 2, 1997 wherein you requested our opinion on whether a terminal loss of $XXXXXXXXXX resulting from the disposition of its mining assets by the corporation formed in an amalgamation of XXXXXXXXXX, should be disallowed in computing the amalgamated corporation's income under the Income Tax Act (the "Act"). ...

The terms of the Holdco I Note will provide that a portion of the interest payable on the note (approximately XXXXXXXXXX %) will be paid in the taxation year the expense is incurred and the unpaid portion will be paid prior to the end of the second taxation year following the taxation year in which the expense was incurred. 19. ...

XXXXXXXXXX will realize a foreign exchange loss of approximately $XXXXXXXXXX on the assumption of Loan 1, as a result of the fluctuation in the exchange rate of US $ on the day of the assumption compared to the rate when the loan was made. 28. ...

XXXXXXXXXX will sell, at fair market value, to Subco XXXXXXXXXX % of its cash and near-cash property and investment property. ...

The Exercise Price will be approximately XXXXXXXXXX % of the market price (on the XXXXXXXXXX Stock Exchange) of the CCo Stock (XXXXXXXXXX) on the date on which the offering of the Units is priced. ...

April 24, 1998 Policy & Procedures Marie-Marthe Gagnon International Audit Division (613) 957-8953 International Tax Directorate Attention: René Fleming, Interim Manager 7-973015 Section 122.3- Overseas Employment Tax Credit This is in reply to your letter of November 12, 1997, requesting our comments concerning the application of the Overseas Employment Tax Credit in a particular factual situation. ...