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

(b) Canco1 and the Lessee entered into a purchase and sale agreement ("Purchase and Sale Agreement ") which provided, inter alia, that Canco1 would sell the XXXXXXXXXX to the Lessee for $XXXXXXXXXX on XXXXXXXXXX or such later agreed date. 4. ...

The rulings are virtually identical except that in this ruling the dividend rate on the preferred shares exceeds the interest rate on the loan by XXXXXXXXXX % whereas in the prior ruling the dividend rate on the preferred shares is equal to the interest rate on the loan. ...

" 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... ...

" 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. ...