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., a taxable Canadian corporation incorporated on XXXXXXXXXX [Business #: XXXXXXXXXX Taxation Centre] and a subsidiary wholly-owned corporation of ForeignCo; (u) "forgiven amount" has the meaning assigned by subsection 80(1) of the Act; (v) "General Partner" means., the general partner of the Limited Partnership; (w) "General Partnership Interest" means the interest of the General Partner in the Limited Partnership entitling General Partner to XXXXXXXXXX% interest in the profits and losses and in the capital of the Limited Partnership remaining after deducting the entitlements of the holders of XXXXXXXXXX Units, if any, and the prior return of the $XXXXXXXXXX entitlement; (x) "Limited Partners" means OpCo, subsequently Amalco, and ForeignCo; (y) "Limited Partnership Agreement" means an agreement to be entered into between General Partner Co. and OpCo as initial limited partner under which the Limited Partnership is constituted and restated with General Partner Co., OpCo and ForeignCo as partners; (z) "ManageCo" means, XXXXXXXXXX, a corporation to be incorporated, the shares of which will be held as described below; (aa) "net capital loss" has the meaning assigned by subsection 111(8) of the Act; (bb) "NewCo means a newly incorporated Canadian subsidiary wholly-owned corporation of ParentCo; (cc) "non-capital loss" has the meaning assigned by subsection 111(8) of the Act; (dd) "OpCo Properties" means the properties of OpCo, including depreciable assets, other capital property, eligible capital property and inventory; (ee) "OpCo" means XXXXXXXXXX, a taxable Canadian corporation incorporated on XXXXXXXXXX [Business No.XXXXXXXXXX Taxation Centre]; (ff) "OpCo Debt" means the indebtedness of OpCo, as described in 14 below; (gg) "OpCo Note" means the non-interest bearing note that will be issued by OpCo to purchase its shares held by ForeignCo; (hh) "paid-up capital" ("PUC") has the meaning assigned by subsection 248(1) of the Act; (ii) "ParentCo" means XXXXXXXXXX, a taxable Canadian corporation constituted under the Company Act, the common shares of which are listed and traded on XXXXXXXXXX Stock Exchange. ...

These rulings are given subject to the limitations and qualifications set forth in Canada Customs & Revenue Agency (the "Agency") Information Circular 70-6R3 dated December 30, 1996, Canada, and are binding upon the Agency provided the Offering is implemented by XXXXXXXXXX. ...

The federal tax account numbers of the parties referred to herein are as follows: Corporate Taxation Centre / Name Account Number Tax Service Office Aco XXXXXXXXXX Bco XXXXXXXXXX Cco XXXXXXXXXX Dco XXXXXXXXXX Eco XXXXXXXXXX Fco XXXXXXXXXX Gco XXXXXXXXXX Hco XXXXXXXXXX Ico XXXXXXXXXX Jco XXXXXXXXXX Kco XXXXXXXXXX Lco XXXXXXXXXX Mco XXXXXXXXXX Nco XXXXXXXXXX Oco XXXXXXXXXX Pco XXXXXXXXXX Qco XXXXXXXXXX Rco XXXXXXXXXX Sco XXXXXXXXXX Tco XXXXXXXXXX Uco XXXXXXXXXX Vco XXXXXXXXXX Wco XXXXXXXXXX Xco XXXXXXXXXX Purpose of the Proposed Transactions The purpose of the proposed transactions is to simplify the corporate structure by eliminating Aco and transfer the employment services directly to the Partnership, thus eliminating the additional administrative effort and costs associated with maintaining Aco; to simplify the planning and administration of each of the Partner Companies by allowing for one allocation of income from the Partnership, rather than an allocation of income from the Partnership and dividend payments to each of the Partner Companies from Aco out of after-tax earnings; and to simplify and facilitate succession planning for the business of the Partnership. ...

Unless otherwise stated, statutory references in this letter are to the Act; "adjusted cost base" (also "ACB") has the meaning assigned by section 54; "controlled foreign affiliate" has the meaning assigned by subsection 95(1); "capital property" has the meaning assigned by section 54; "dividend rental arrangement" has the meaning assigned by subsection 248(1); " FMV" means fair market value; "guarantee agreement" has the meaning assigned by subsection 112(2.2); XXXXXXXXXX "paid-up capital" has the meaning assigned by subsection 89(1); "proceeds of disposition" has the meaning assigned by section 54; "public corporation" has the meaning assigned by subsection 89(1); "stated capital" has the meaning assigned by the XXXXXXXXXX; "taxable Canadian corporation" has the meaning assigned by subsection 89(1); "taxable dividend" has the meaning assigned by subsection 89(1); and "unrelated person" has the meaning assigned by subsection 55(3.01). ...

In XXXXXXXXXX, Dco acquired all of the XXXXXXXXXX was the subject matter of an advance income tax ruling # XXXXXXXXXX issued by the CCRA on XXXXXXXXXX. 13. ...

Consolidated revenues of I Ltd. for the year ended XXXXXXXXXX totaled US $ XXXXXXXXXX with consolidated net earnings amounting to US $XXXXXXXXXX. 5. ...

Under the terms of the Settlement Agreement agreed to by the initial executors and trustees of the Estate, the Late Wife, Child A, Child B and the Charity: (a) cash payments of $XXXXXXXXXX and $XXXXXXXXXX were to be made by the Estate to Child A and Child B, respectively; and (b) the Charity agreed to pay to Child A XXXXXXXXXX % of the value of the assets it receives from the Estate. ...

The foregoing computation of the purchase price per Unit payable by ParentCo in shares of its capital stock is subject to subsection 25(3) of the CBCA, which provides: " A share shall not be issued until the consideration for the share is fully paid in money or in property or past services that are not less in value than the fair equivalent of the money that the corporation would have received if the share had been issued for money. ...

Principal Issues: 1. whether LP Units are tax shelters 2. whether existence of call option causes no REOP 3. whether existence of call option is 96(2.2)(d) benefit 4. whether gaar applies 5. whether, where a trust receives mixed income (split and nonsplit), trust may designate payments to beneficiaries Position: 1. no 2. not in and of itself 3. not in and of itself 4. maybe, if call option is exercised and 24 month period in 110.6(2.1) avoided 5. yes, as long as nonsplit income allocated to beneficiaries does not exceed non-split income of trust Reasons: 1. limited partners cannot receive cumulative losses that are greater than XXXXXXXXXX % of their capital contribution 2. must consider all facts re REOP 3. call option is at discretion of general partner, not limited partners/ option price is fmv 4. 110.6 5. law does not prohibit streaming or require equal payouts of split and nonsplit income XXXXXXXXXX 2001-006921 XXXXXXXXXX, 2001 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX We are writing in response to your letter of XXXXXXXXXX, wherein you requested an advance income tax ruling, and your subsequent correspondence and our (XXXXXXXXXX) telephone discussions concerning this ruling request. ...

.), as amended, and unless otherwise stated, every reference herein to a section, subsection, paragraph or subparagraph is a reference to the relevant provision of the Act; (b) "adjusted cost base" (also referred to as "ACB") has the meaning assigned by section 54; (c) "agreed amount" in respect of property means the amount that the transferor and the transferee of the property have agreed upon in their election under subsection 85(1) in respect of the property; (d) "BCA" means the "Canada Business Corporations Act "; (e) "capital dividend" has the meaning assigned in subsection 83(2); (f) "capital dividend account" (also referred to as "CDA") has the meaning assigned by subsection 89(1); (g) "capital property" has the meaning assigned by section 54; (h) "cost amount" has the meaning assigned by subsection 248(1); (i) "dividend refund" has the meaning assigned by subsection 129(1); (j) "eligible property" has the meaning assigned by subsection 85(1.1); (k) "Mr.A" refers to the late XXXXXXXXXX; (l) "Mrs. ...