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Subject to the application of the provisions of subsection 26(5) of the ITAR, and to the application of subsection 69(11) and for the application of paragraph 88(2.2)(b), which applies for the purposes stated in the preamble to subsection 88(2.2), subsection 85(1) will apply to the transfer of each eligible property owned by DC to the particular Property Transferee, as described in paragraphs 19 & 20 above, provided each Particular Transferee and DC file a valid election in respect of such transfer, as described in paragraph 21 above, such that the agreed amount in respect of each such transfer shall be deemed to be the proceeds of disposition thereof to DC and the cost thereof to each such Property Transferee pursuant to paragraph 85(1)(a). ...

.), c.1 as amended to the date hereof, and unless otherwise stated, every reference herein to a part, section, subsection, paragraph or subparagraph is a reference to the relevant provisions of the Act; (b) "adjusted cost base" has the meaning assigned by section 54 and subsection 248(1); (b) "agreed amount" in respect of a property means the amount that the transferor and transferee of the property have agreed upon in their election under subsection 85(1) in respect of the property; (d) "BCA-XXXXXXXXXX " means Business Corporations Act of XXXXXXXXXX; (e) "CBCA" means Canada Business Corporations Act; (f) "CCRA" means, on or after November 1, 1999, the Canada Customs and Revenue Agency, and before November 1, 1999, Revenue Canada, Taxation; (g) "Canadian-controlled private corporation" has the meaning assigned by subsection 125(7); (h) "capital dividend account" has the meaning assigned by subsection 89(1); (i) "capital property" has the meaning assigned by section 54; (j) "distribution" has the meaning assigned by subsection 55(1); (k) "dividend rental arrangement" has the meaning assigned by subsection 248(1); (l) "eligible property" has the meaning assigned by subsection 85(1.1); (m) "guarantee agreement" has the meaning assigned by subsection 112(2.2); (n) "forgiven amount" has the meaning assigned by subsections 80(1) and 80.01(1); (o) "ITAR" means the Income Tax Application Rules; (p) "paid-up capital" has the meaning assigned by subsection 89(1); (q) "Paragraph" means a numbered paragraph in this letter; (r) "pre-1972 CSOH" means "pre-1972 capital surplus on hand" which has the meaning assigned by subsection 88(2.1); (s) "private corporation" has the meaning assigned by subsection 89(1); (t) "RDTOH" means "refundable dividend tax on hand" which has the meaning assigned by subsection 129(3); (u) "Regulations" means the Income Tax Regulations; (v) "specified financial institution" has the meaning assigned by subsection 248(1); (w) "specified investment business" has the meaning assigned by subsection 248(1); and (x) "taxable Canadian corporation" has the meaning assigned by subsection 89(1). ...

No Reasons: Please refer to the analysis in the document March 22, 2001 INTERNATIONAL TAX DIRECTORATE HEADQUARTERS Transfer Pricing & Alison Campbell Competent Authority Attention: Tam Nguyen 2000-004916 XXXXXXXXXX Canadian Investment Fund- Unregistered Reinsurance Reserve XXXXXXXXXX Taxation Years (Your File XXXXXXXXXX) This is in reply to your memorandum of September 25, 2000, regarding the XXXXXXXXXX and its Canadian branch, hereinafter referred to as USCo and the Branch, respectively. ...

The only remaining property will be Series 2 shares and Company A will receive XXXXXXXXXX % of the remaining Series 2 shares and the limited partners of LP A will receive XXXXXXXXXX% of the remaining Series 2 shares, in proportion to the number of such limited partnership units held. ...

Subco1's authorized share capital will include at least one class of voting common shares and Class "A" shares which will be non-voting, non-participating preferred shares bearing a discretionary non-cumulative dividend of up to XXXXXXXXXX % per month and redeemable at the option of the corporation or shareholder for an amount equal to the fair market value of the amount received by the corporation as consideration for the share. ...

The purpose test in 104(7.1) is not met, namely the main purpose of the proposed transactions is to reduce the administrative complexity of the Reduced Management Fee program & to enable the manager to effectively market the units to differing groups of Investors. ...

., as part of the public offering, will purchase and hold, at the outset, XXXXXXXXXX % of the issued MFT units. ...

Newco will add to the stated capital account maintained for its Newco Preferred Shares an amount equal to the amount by which the aggregate of: (a) the cost amounts, in the case of eligible properties, (b) the fair market value, in the case of other properties, and (c) the amount of the XXXXXXXXXX/Aco Promissory Note 2 transferred to XXXXXXXXXX/Bco exceeds (d) the amount equal to XXXXXXXXXX % of the Liabilities assumed by Newco. 20. ...

Propertyco also owns a XXXXXXXXXX % co-ownership interest (the "Interest") in XXXXXXXXXX lands, facilities and chattels and related inventories, accounts receivable and deposits (collectively, the "Facility”) that Propertyco and an arm's length third party (XXXXXXXXXX, or the “Co-owner") hold as equal tenants-in-common. ...

OPCO owns, inter alia, XXXXXXXXXX% of the shares of XXXXXXXXXX ("XXXXXXXXXX CO "), a company incorporated under the laws of XXXXXXXXXX and engaged in marketing, distributing and selling Products for the U.S. ...