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XXXXXXXXXX Holdco owns XXXXXXXXXX % of the issued and outstanding shares of XXXXXXXXXX. 27. ... Yours truly, XXXXXXXXXX Section Manager For Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

The amount to be added to the stated capital of the Newco4 class A common shares so issued will be an amount equal to the aggregate adjusted cost base of the common shares of Pubco so transferred (the "Transferred Shares "4 ""). 15. ... Jco will designate, in respect of the Transferred Shares "1", the Transferred Shares "2", the Transferred Shares "3" and the Transferred Shares "4"in its income tax return of income for the taxation year in which each of Newco1, Newco2, Newco3 and Newco4 is wound up, an amount pursuant to paragraph 88(l)(d), equal to the difference between: (a) the purchase price paid by Jco for the shares of Newco1, Newco2, Newco3 and Newco4, as the case may be, as described in paragraph 16 above; and (b) the adjusted cost base to Newco1, Newco2, Newco3 and Newco4, as the case may be, of the Transferred Shares "1", the Transferred Shares "2", the "Transferred Shares "3", and the "Transferred Shares "4" (hereinafter sometimes collectively referred to, together with the "Transferred Shares "A" and the "Transferred Shares "B", as the "Transferred Shares "), as the case may be, as a result of the transaction described in paragraph 14 above. 19. ...

Principal Issues: • butterfly ruling- similar to other given in past Position:- favorable ruling given Reasons: no new issues XXXXXXXXXX 962858 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 1997 Dear Sir/Madam: Re: XXXXXXXXXX Advance Income Tax Ruling We are writing in response to your letter of XXXXXXXXXX wherein you requested an advance income tax ruling on behalf of the above referenced taxpayers. ... The issued and outstanding shares of DC are as follows: Class & Number Shareholder of Shares PUC ACB XXXXXXXXXX The shares of DC represent capital property to each of the shareholders referred to above. ...

FIRST NATIONS WORKSHOP Pacific Region May 4- 5, 1998 Paper presented by Roberta Albert Introduction The Income Tax Rulings & Interpretations Directorate is part of the Policy and Legislation Branch. ... The Income Tax Rulings & Interpretations Directorate plays a consultative role in the Department. ...

The details of the Mortgage Loans and the Operating Lines (collectively, the "Loans"), totalling approximately $XXXXXXXXXX, which are owed to the Lenders and which the Debtor proposes to refinance with preferred shares are as follows and as described in 11 below: LENDER PROPERTY INTEREST RATE PRINCIPAL % AMOUNT XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX 11. The principal amounts as of XXXXXXXXXX, and interest rates (XXXXXXXXXX) on the Operating Lines with Lender A are as follows: PRINCIPAL AMOUNT INTEREST RATE RATE EXPIRY DATE % XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX 12. ...

Principal Issues: Various Indian taxation issues:- employment income- investment income- business income INDIAN ACT EXEMPTION ISSUE CONFERENCE Prairie & Pacific Regions November 20- 21, 1996 INCOME TAX RULINGS AND INTERPRETATIONS DIRECTORATE Introduction The Income Tax Rulings & Interpretations Directorate is part of the Policy and Legislation Branch. ...

Reasons: XCO will own XXXXXXXXXX % of the voting shares of Aco and will not have de-jure control. ... Aco will transfer its intellectual property, remaining cash and fixed assets, other than the building XXXXXXXXXX (the "XXXXXXXXXX Building"), to PartnershipB and as consideration therefor, PartnershipB will assume all of Aco's liabilities, XXXXXXXXXX its bank loan, and issue to Aco a limited partnership interest and a general partnership interest entitling it to XXXXXXXXXX % and XXXXXXXXXX% of the income or loss of PartnershipB, respectively. ...

Initially, pursuant to the XXXXXXXXXX First Lease, the XXXXXXXXXX was leased by B Co, as landlord, to XXXXXXXXXX, as to an undivided XXXXXXXXXX% interest, D Co as nominee for A Co and partnerships whose interests A Co subsequently acquired, as to an undivided XXXXXXXXXX % interest, and Z Co as to an undivided XXXXXXXXXX% interest. ... Provided that A Co's XXXXXXXXXX % share of the Current XXXXXXXXXX Monthly XXXXXXXXXX Land Rent or A Co's Current XXXXXXXXXX Land Rent payable in respect of any period on or after the date of the issuance of this ruling is incurred by A Co for the purpose of gaining or producing income from a business or property of A Co, such payments will be deductible by A Co, pursuant to subsection 9(1) of the Act, for the purpose of computing its income from such business or property, as the case may be. ...

& Mrs. B (who have attained the age of eighteen (18) years). The sole capital beneficiaries will be Mr. ... & Mrs. B. e) The trustees shall have unfettered discretion to make payments of income or capital of the trust fund to or for the benefit of any one or more of the income beneficiaries at any time prior to the distribution date. ...

The beneficial ownership, aggregate ACB and PUC and the aggregate percentage of votes associated with the shares in the capital of Aco are as follows: Shareholder Class of Shares Number of Shares ACB PUC Percentage of Votes Daughter 1 Common XXXXXXXXXX $XXXXXXXXXX $XXXXXXXX XXXXXXXXX Daughter 2 Common XXXXXXXXXX $XXXXXXXXXX $XXXXXXXX XXXXXXXXX The FMV of the common shares in the capital of Aco is substantially in excess of Daughter 1 & Daughter 2's ACB. ... The BcoSub Note will be set off against the Aco Note # 1 and they will be cancelled. ...