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Parent B is a XXXXXXXXXX % limited partner in Parent A, GP is a XXXXXXXXXX % general partner in Parent A and XXXXXXXXXX is a XXXXXXXXXX limited partner in Parent A. ... On XXXXXXXXXX, Parent B exercised through its wholly owned subsidiary, BCo, the Option by acquiring from ACo XXXXXXXXXX % of the units of AB Partnership. As a result, BCo now owns XXXXXXXXXX % of the issued and outstanding units of AB Partnership, while ACo owns the remaining XXXXXXXXXX % of the issued and outstanding units of AB Partnership. ...

2009 Ruling 2009-0336261R3- transferable warrants & flow through shares Unedited CRA Tags 66(15); 66(12.6); 66(12.66) Principal Issues: 1. whether transferable flow-through warrants qualify as FTS Position: 1.if all conditions of definition in 66(15) met at the time warrant is exercised Reasons: 1. based on proposed transactions "agreement in writing" and other required conditions will be met when warrant is exercised XXXXXXXXXX 2009-033626 XXXXXXXXXX, 2009 Dear. ... The common shares of the Corporation are listed on the XXXXXXXXXX under the ticker symbol "XXXXXXXXXX " and are widely held by the public. 4. ... In particular, nothing in this letter should be interpreted as confirming, either expressly or implicitly: (i) whether the Corporation is a principal-business corporation; (ii) whether any particular expense incurred or to be incurred by the Corporation will qualify as CEE; (iii) whether any particular expense incurred or to be incurred by the Corporation will constitute a prescribed Canadian exploration and development overhead expense; (iv) the determination of whether the Warrant Shares will constitute prescribed shares; (v) the reasonableness of the allocation of the $ XXXXXXXXXX subscription price payable for a Series B Unit as described in paragraph 5(iii); and (vi) the computation of the adjusted cost base of the Series B Warrant to the Holder and the computation of the cost of the Warrant Share to the Holder and, in particular, the interaction of subsections 49(3) and 66.3(3). ...

2007 Ruling 2006-0215921R3 F- Don à une municipalité / 149(1)l) Unedited CRA Tags 248(31) 248(32) 149(1)l) Principales Questions: (1) Quel est le montant admissible d'un don fait à une municipalité lorsque la municipalité entend verser un montant équivalent à un organisme sans but lucratif (OSBL) à la suite du don? ... Entité C XXXXXXXXXX Entité D XXXXXXXXXX Entité E XXXXXXXXXX Entité F DÉFINITION DES TERMES Don Le don à être effectué par Société A à Entité B d'un montant de XXXXXXXXXX $. ... Montant du Don XXXXXXXXXX $. Période La durée de l'Emphytéose qui sera, au minimum, de XXXXXXXXXX ans. ...

2005 Ruling 2004-0096171R3- Treaty Benefits & Carrying Business in Canada Unedited CRA Tags 2(3) Principal Issues: 1) Whether the US corporation will be entitled to the benefits of the treaty notwithstanding the proposed transaction? ... For XXXXXXXXXX, approximately XXXXXXXXXX % of THE GROUP "Americas" revenue was from Canadian customers. ...

2007 Ruling 2007-0235881R3- Class of German Arrangement & Treaty Benefits Principal Issues: 1. ... In this letter, unless otherwise noted all statutory references are to the Income Tax Act (Canada), R.S.C. 1985, 5th Supplement, c. 1, as amended, (the "Act") each "technical" tax term used in this request has the same meaning as it has for purposes of the Act and each monetary reference is to CDN $. ... The Fund will be the only limited partner of the LP and will hold a XXXXXXXXXX% limited partnership interest and Newco will be the only general partner of the LP and will hold a XXXXXXXXXX % general partnership interest. 42. ...

2014 Ruling 2014-0532411R3- Convertible Notes & Part XIII Tax CRA Tags 212(3) 212(1)(b) 214(7) Principal Issues: In the event of a conversion of a convertible note for common shares, whether the excess (if any) determined under subsection 214(7) would constitute "participating debt interest" as defined in subsection 212(3)? ...

2000 Ruling 1999-0012763- Class 43-1 System & Heat Rate Requirements Unedited CRA Tags class 43-1 1104(14) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

2001 Ruling 2001-0109363- HEALTH & WELFARE TRUST Unedited CRA Tags 248(1) 6(1)(a)(i) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ...

FUND XXXXXXXXXX currently has a total of approximately XXXXXXXXXX institutional investors with an average investment of € XXXXXXXXXX. ... As at XXXXXXXXXX, the value of FUND XXXXXXXXXX's net investments was € XXXXXXXXXX, and XXXXXXXXXX% of FUND XXXXXXXXXX's investments consisted of liquid assets, which are invested so as to ensure that there is always sufficient liquidity available for future redemptions and to fund property acquisitions that are continually under active consideration by GERMANCO on behalf of FUND XXXXXXXXXX. 8. As at XXXXXXXXXX, the value of FUND XXXXXXXXXX's net investments was € XXXXXXXXXX, and XXXXXXXXXX% of FUND XXXXXXXXXX's investments consisted of liquid assets, which are invested so as to ensure that there is always sufficient liquidity available for future redemptions and to fund property acquisitions that are continually under active consideration by GERMANCO on behalf of the FUND XXXXXXXXXX. 9. ...

2004 Ruling 2004-0099651R3- Migration to Canada / PUC Reduction Unedited CRA Tags XXXXXXXXXX 84(4.1) Principal Issues: 1. ... Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate ...