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

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

The Queen, 2004 DTC 3300, at page 3309, determining whether a child is a "child of the marriage" is not an easy task: "However, the issue of whether one remains 'a child of the marriage' in accordance with the Divorce Act can be a tricky issue to resolve and will- in most cases, barring consent- require a decision by a competent tribunal. [...] ...

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, and are binding upon the Agency provided the Plan is implemented on or before XXXXXXXXXX. ...

Position TAKEN 1) Yes 2) No 3) No Reasons FOR POSITION TAKEN The position taken with respect to the allocation of capital gains to redeeming unitholders and for determining the proceeds of disposition on such redemptions is consistent with the position taken in a previous ruling (Doc # 981758). ...

For example, see the definition "loan" adopted in McVey and McVey 2 and Simmonds & Sons. 3 In this case, there does not appear to have been any advance of funds from the taxpayer to the landlords or to third persons at the direction of the landlords. ...

It is anticipated that the transfer agreement referred to in 7 above will contemplate that the transfer of assets to the XXXXXXXXXX Funds may need to occur in more than one stage although a substantial (over XXXXXXXXXX % on a market value basis) portion of the assets likely will be transferred at one stage following the obtaining of regulatory approval. ...

The UK Co-Producer will receive an up-front advance (the "Advance") from the Film Partnership, representing approximately XXXXXXXXXX % of the Rights Payment. ...

Memo to File Re: XXXXXXXXXX Test Wind Turbines Canadian Renewable & Conservation Expense Prepared by Peter Lee September 12, 2001 #2001-009629 Background Even though Natural Resources Canada ("NR Can") have reviewed and provided opinions on several wind farm projects in respect of the "test-wind-turbine" issue for the purposes of subsection 1219(3) of the Income Tax Regulations (the "Regulations") and subsection 66.1(6) of the Income Tax Act (the "Act"), CCRA have not been consulted with and no advance income tax rulings have been requested and given on these projects. ...

The Employer's annual contributions to the RPP are set out in the RPP and are XXXXXXXXXX% of a Member's Earnings up to the YMPE plus XXXXXXXXXX % of the Member's Earnings in excess of the YMPE. 4. ...