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Proposed subparagraph 73(1.01)(c)(ii) of the Act provides inter alia that the transfer of capital property by an individual to a trust under which "... the individual is entitled to receive all of the income of the trust that arises before the individual's death and no person except the individual may, before the individual's death, receive or otherwise obtain the use of any of the income or capital of the trust... ...

Under the proposed legislation, the trust would have neither a resident contributor nor a resident beneficiary. 2. 233.2, 233.3 & 233.6 XXXXXXXXXX 2001-007770 Annemarie Humenuk May 2, 2001 Dear XXXXXXXXXX: Re: Offshore Family Trusts This is in reply to your letter of January 26, 2001, addressed to the Toronto Centre Tax Services Office concerning the potential Canadian tax liability and filing requirements in respect of an offshore family trust settled by a non-resident of Canada. ...

Yours truly, XXXXXXXXXX for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

., 2001 DTC 72, à la page 86: "... qu'il sera rempli [le deuxième critère] si une personne ne fait que participer à une opération, non pour son propre bénéfice mais pour celui de quelqu'un d'autre ou, même s'il agit pour son propre bénéfice, s'il agit aussi pour quelqu'un d'autre dans un contexte de réciprocité. ...

Subsection 73(3) states, in part, that "... the property was, before the transfer, used principally in the business of farming... ...

These rulings are provided subject to the limitations and qualifications set out in Information Circular 70-6R4 issued by the Canada Customs & Revenue Agency on January 29, 2001 and are binding upon the Agency provided that the proposed transactions are completed on or before XXXXXXXXXX. ...

The reference to "Supplemental Plan is implemented by XXXXXXXXXX " in the last paragraph is hereby deleted and replaced by "proposed transactions are completed by XXXXXXXXXX". ...

The number of Shares that a Participant is entitled to acquire under his or her options is computed by taking the Participant's projected savings (interest included) (the "Projected Savings") in respect of the particular election and dividing by XXXXXXXXXX % of the market price of the Shares of Parent on the date that the Participant elected to participate in the Plan. ...

For Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

Since the amount received is included in income, it would not cause the plan to fall outside the guidelines in IT-529. 2 & 4. ...