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" In addition to the above test, the expenses must meet the additional test imposed by the preamble to subsection 20(1) of the Act which is, "... there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto... ...

The original shareholdings of DC on incorporation were as follows: Shareholder Number of shares % Class of shares Stated capital W XXXXXXXXXX "A" $XXXXXXXXXX S XXXXXXXXXX "A" $XXXXXXXXXX 8. ...

M Class A Preference XXXXXXX XXXXXXX XXXXXXX Bco Common XXXXXXX XXXXXXX XXXXXXX Cco Common XXXXXXX XXXXXXX XXXXXXX The Class A Preference shares of Aco are non-voting, redeemable, retractable for an amount of $XXXXXXXXXX and entitled to non-cumulative dividends at the rate of XXXXXXXXXX % per annum of the redemption amount. ...

The General Partner will receive an undivided XXXXXXXXXX% interest in the preferred shares distributed, and the Limited Partners will receive an undivided XXXXXXXXXX % interest in the preferred shares distributed. 40. ...

CCo's subscription amount will be $XXXXXXXXXX and its subscription will represent approximately XXXXXXXXXX % of all the issued shares of the Fund. ...

Canco owns approximately XXXXXXXXXX % of the shares of the capital stock of Foreign Affiliate #2, which is a controlled foreign affiliate of Canco. ...

Position: 1 & 2. Yes. 3. Provided that the trustee does not elect under subsection 107(2.001), yes. 4. ...

The authorized capital of Newco will include: (a) voting, common shares with a par value of $XXXXXXXXXX per share; and (b) XXXXXXXXXX non-voting, no par value, redeemable and retractable preferred shares which will be entitled to receive, as and when declared, non-cumulative dividends not exceeding XXXXXXXXXX % per annum of the redemption amount. ...

For the purpose of this paragraph, the expression "approximate that proportion" means that the discrepancy from that proportion, if any, would not exceed XXXXXXXXXX %, determined as a percentage of the FMV of each type of property which Transferee has received as compared to what the Transferee would have received had it received its appropriate pro rata share of the FMV of that type of property. 24. ...

Yours truly, XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...