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Partnership will assume the O & M Agreement such that the XXXXXXXXXX Assets will be operated in substantially the same manner a before their transfer to Partnership. 18. ... It is not anticipated that any prospective Debenture Holder will hold more than XXXXXXXXXX % of the units of Income Fund. ...

XXXXXXXXXX prior ruling (file # 972815) re: identical transaction (transaction was not completed). 2. ... On the Redemption Date, ACO will be required to make a cash payment equal to the Redemption Price to those Holders who surrender their Units for redemption. g) If a Fundamental Change of Control (as defined below) of BCO occurs, each Holder will have the right, at the Holder's option, to require ACO to purchase all or any part of the Holder's Units on the date (the "Repurchase Date") that is XXXXXXXXXX days after the date ACO gives notice of the Fundamental Change of Control at a price (the "Repurchase Price") equal to XXXXXXXXXX % of their Principal Amount plus accrued Interest to the Repurchase Date, after which the related Warrants will automatically expire. ...

Note " means the interest-bearing promissory note in the principal amount of USD$XXXXXXXXXX issued by ULC to U.S. ... Yours truly, XXXXXXXXXX Section Manager For Division Director International Section I Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

On XXXXXXXXXX, Eco used part of its excess funds to make an interest free loan of $ XXXXXXXXXX to Cco (the “Cco Loan”). 20. On XXXXXXXXXX, Cco, with the proceeds from the Cco Loan, made an interest free loan of $ XXXXXXXXXX to Aco (the “Aco Loan 2”). ...

., c. 95, as amended; (bb) “Stock Exchange” means the XXXXXXXXXX; (cc) “Sub-Custodian” means XXXXXXXXXX; (dd) “Sub-Custodian’s Parent” means XXXXXXXXXX; (ee) “subsidiary wholly-owned corporation” has the meaning assigned by subsection 248(1) of the Act; (ff) “Tax Treaty” has the meaning assigned by subsection 248(1) of the Act; (gg) XXXXXXXXXX; (hh) “TLCA” means the Trust & Loans Companies Act (S.C. 1991, c. 45); (ii) “Unit(s)” means a unit of account, representing a proportionate undivided co-ownership interest in the assets of the Fund, as tenants in common with the other Unitholders. ... The executive partners own XXXXXXXXXX % of the Investment Manager with the remaining XXXXXXXXXX% owned by investors. ...

The explanatory notes to paragraph 20(1)(e) state: Paragraph 20(1)(e) is amended to clarify that it does not allow a deduction for profit participation and similar payments — that is, payments dependent on the use of or production from property, or computed by reference to revenue, profits, cash flow, commodity prices or any other similar criterion or by reference to dividend payments. Where such payments are compensation for the use of borrowed money or for the right to pay a debt over time, they would be excluded by the existing paragraph 20(1)(e) — either because they are interest or because they fall within the broad definition of “principal amount” in subsection 248(1). ...

Civil Law Trust Richard Tremblay and Kim Wharram (footnote 11) summarize the most important characteristics of a civil law trust as follows: “… articles 1256 to 1298 of the new Civil Code of Quebec… now provide for a comprehensive trust regime that includes provisions for transfers of property to a trustee, and the administration of the trust property by the trustee… While this trust regime contains many concepts that are similar to common law principles relating to trusts, there are some notable distinctions. ... For Director International & Trusts Division Income Tax Rulings Directorate FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 We do not know whether XXXXXXXXXX acted pursuant to the directions of XXXXXXXXXX. 2 However, at this time, XXXXXXXXXX was the Supervisor and per Article XXXXXXXXXX of the Articles of the Foundation, only XXXXXXXXXX could have appointed a new Supervisor. 3 We did not assess the Canadian income tax consequences of the change in Beneficiaries of the Foundation. 4 However, we question whether, pursuant to the laws of the Netherlands Antilles, a person can be the Founder (i.e. ...

After degassing, the emulsion will be cooled through a heat exchanger to approximately XXXXXXXXXX ° C. (iv) Emulsion Treating System: The water content in the bitumen will typically be less than XXXXXXXXXX % as the bitumen leaves the production separation system and is split into two streams that feed the XXXXXXXXXX treaters. ...

All of the authorized Series A Preferred Shares are issued and outstanding and are owned by XXXXXXXXXX ULC. 10) The Series A Preferred Shares have the following attributes: a) redeemable and retractable no sooner than XXXXXXXXXX years after the day following the date of issue for an amount (the "Redemption Amount") equal to $XXXXXXXXXX US in aggregate; b) voting, with a fixed cumulative annually-compounding dividend equal to XXXXXXXXXX % of the Redemption Amount plus any unpaid dividends from all prior years- no dividend may be paid on any other class of shares which would impair US Opco's ability to redeem the Series A Preferred Shares at the Redemption Amount. 11) The ACB of the Series A Preferred Shares is equal to the elected amount that was claimed under a section 85 election in respect of the transfer of XXXXXXXXXX Foreign Affiliates by XXXXXXXXXX ULC to US Opco at the time of the issuance of the shares. ... PROPOSED TRANSACTIONS Sale of Series A Preferred Shares 23) Prior to XXXXXXXXXX,XXXXXXXXXX ULC will sell a minimum of XXXXXXXXXX % of the Series A Preferred Shares of US Opco to US Subco for proceeds of disposition equal to the then fair market value of the shares. ...

Subco is a taxable Canadian corporation, XXXXXXXXXX % of the shares of which were, prior to XXXXXXXXXX, owned by Targetco1. ... The XXXXXXXXXX % of the shares of Subco have, at all times, been owned by a person dealing at arm's length with Targetco1 and Aco. 5. ...