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Yours truly, XXXXXXXXXX For Director International Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

$XXXXXXXXXX ÷ U.S.$XXXXXXXXXX) would have been issued. This differential likely indicates that the conversion did not occur pursuant to the terms of the Notes. ...

Pursuant to the Plan, the Interest on Notes A and Notes C is computed daily on the basis of the Bank of Canada average XXXXXXXXXX month BA rate, while the Interest on Notes B is computed daily on the basis of the Bank of Canada average XXXXXXXXXX month BA rate + XXXXXXXXXX%. 18. ...

Yours truly, XXXXXXXXXX For Director International Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

Reasons: (1) & (2) The lump sum payment is not considered a qualifying "support amount" for purposes of paragraphs 56(1)(b) and 60(b) of the Act. ...

In the event the trust is revoked under this Section XXXXXXXXXX, the Trustee shall forthwith distribute the entire then trust estate of the trust in the following shares – XXXXXXXXXX to Mother and XXXXXXXXXX each to the Children. ...

Definitions In this letter, unless otherwise stated, the following terms have the meaning specified below: (a) "adjusted cost base" " has the meaning assigned to that term in section 54 of the Act; (b) "Business" means the business of XXXXXXXXXX located adjacent to the Properties; (c) "Canco" means XXXXXXXXXX; (d) "capital property" has the meaning assigned to that term in section 54 of the Act; (e) "controlled foreign affiliate" has the meaning assigned to that term in subsection 95(1) of the Act; (f) "Country X" means XXXXXXXXXX; (g) "CRA" means Canada Revenue Agency; (h) "designated liquidation and dissolution" has the meaning assigned to the term in subsection 95(1) of the Act; (i) "excluded property" has the meaning assigned to that term in subsection 95(1) of the Act; (j) "foreign accrual property income", also referred to herein as "FAPI", has the meaning assigned to that term in subsection 95(1) of the Act; (k) "foreign affiliate" has the meaning assigned to that term in subsection 95(1) of the Act; (l) "Foreign Corp" means XXXXXXXXXX; (m) "Foreign Holdco" means XXXXXXXXXX; (n) "Foreign LP" means XXXXXXXXXX; (o) "foreign resource property" has the meaning assigned to that term in subsection 66(15) of the Act; (p) "Foreign Subco1" means XXXXXXXXXX; (q) "Foreign Subco2" means XXXXXXXXXX; (r) "Foreign Subco3" means XXXXXXXXXX; (s) "Foreign Subco4" means XXXXXXXXXX; (t) "Mine 1" means XXXXXXXXXX located in XXXXXXXXXX; (u) "Mine 2" means XXXXXXXXXX located in XXXXXXXXXX; (v) XXXXXXXXXX; (w) "Parent" means XXXXXXXXXX; (x) "proceeds of disposition" has the meaning assigned to that term in section 54 of the Act; (y) "Properties" means Mine 1 and Mine 2, collectively; (z) "public corporation" has the meaning assigned to that term in subsection 89(1) of the Act; (aa) XXXXXXXXXX; (bb) XXXXXXXXXX; (cc) XXXXXXXXXX; (dd) XXXXXXXXXX; (ee) "taxable Canadian corporation" has the meaning assigned to that term in subsection 89(1) of the Act; and (ff) "US$" means United States dollars. ...

Generally, in files where the status of XXXXXXXXXX MRPS as equity – as opposed to debt or some other type of instrument- was relevant, Rulings accepted that such MRPS would be treated as equity for purposes of the Act. ...

September 20, 2002 International Policy & Business HEADQUARTERS Management Division Income Tax Rulings Directorate Policy and Publications Unit I S. ...

In the past, XXXXXXXXXX Holdco 2 has been used to directly or indirectly acquire XXXXXXXXXX % of the shares of selected active businesses operating outside of Canada and XXXXXXXXXX from arm’s length persons. ...