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To the extent that it relates to a past transaction you should contact the appropriate Tax Services Office ("TSO") of the Canada Customs & Revenue Agency (the "CCRA"). ...

Réponse de l'ADRC Selon le paragraphe 181.1(1) de la Loi, toute société est tenue de payer un impôt en vertu de la Partie I.3 de la Loi qui correspond à 0,225 % de l'excédent éventuel de son capital imposable utilisé au Canada pour une année d'imposition sur son abattement de capital pour l'année. ...

" You advised in your aforementioned letter: "... a number of meetings were held between industry representatives and representatives of the Department of Finance in order to broaden the transitional relief...Ultimately, it was agreed that one of the criteria would be that the production services limited partnership had begun incurring production expenses prior to September 18, 2001. ...

Our comments in # 1 above would have application to this situation. 5) Our position concerning arrangements whereby employees are able to select the type and level of coverage from a menu of available benefits (sometimes referred to as "cafeteria plans" or "flexible benefit programs") is discussed in Interpretation Bulletin IT-529, "Flexible Employee Benefit Programs". ...

If the "Total Shareholder Return" exceeds the Benchmark and is in the top quartile at the end of the third year of the Plan, then all Share awards will vest at that time and an additional XXXXXXXXXX % of the original number of Shares awarded will be added; b. ...

The collection is effected by deeming a dividend to have been paid to the non-resident insurer that is subject to withholding tax at a rate of 25 % under Part XIII of the Act. ...

., e.g. a church, school, college, hospital, asylum, reformatory, mission or the like; [...] ...

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

" 7. Paragraph 36 will be amended to read as follows: Oco will redeem all of its Oco XXXXXXXXXX Shares held by Cco for an amount equal to their fair market value, being the Oco XXXXXXXXXX Aggregate Redemption Amount. ...

Funds qualified before proposed transactions & proposed transactions will not disqualify. ...