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February 25, 2003 XXXXXXXXXX TSO HEADQUARTERS Business Enquiries Financial Institutions Section Verification & Enforcement Division Income Tax Rulings Directorate Attention: XXXXXXXXXX Alison Campbell (613) 957-3496 2003-000167 Demutualization Payments to Employees We are replying to your request for assistance in determining the appropriate application of section 139.1 of the Income Tax Act, in respect of a particular taxpayer. ...

Consequently, its four founding shareholders currently own the common shares of Lossco as follows: Shareholder # of common shares Country of Residence Profitco XXXXXXXXXX Canada Forco1 XXXXXXXXXX United States XXXXXXXXXX ("Forco2") XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX ("Forco3") XXXXXXXXXX XXXXXXXXXX Profitco's aggregate adjusted cost base and aggregate paid-up capital attributable to its XXXXXXXXXX common shares of Lossco is $XXXXXXXXXX. 5. ...

"investment tax credit" " has the meaning assigned to that expression by subsection 127(9) of the Act. ...

These shares represented XXXXXXXXXX % of the issued and outstanding share capital of XXXXXXXXXX, respectively. 7.1 XXXXXXXXXX. 7.2 XXXXXXXXXX. 7.3 XXXXXXXXXX. 7.4 XXXXXXXXXX. 8. ...

We trust that our comments will be of assistance to you. for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

. $ XXXXXXXXXX): XXXXXXXXXX. PROPOSED TRANSACTIONS The parties propose to enter into the following transactions on a date (the "Transaction Date") as early as practical after receiving the rulings given in this letter, provincial tax rulings, United States tax rulings and XXXXXXXXXX: 17. ...

Although the word "exclusively " is used in paragraph 149(1)(l) of the Act, the Agency has taken the position a corporation may carry on income generating activities and earn income and still qualify for exempt status provided that there is a causal relationship between the profit making activity and the exempt purpose of the corporation. ...

The Band Council only owned XXXXXXXXXX % of the shares. De facto control of the corporation was not with a person exempt from tax under section 149. ...

To the best of your knowledge, and that of the taxpayer involved, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayer or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or a related person; (iii) under objection by the taxpayer or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ...

Department of Fisheries & Oceans Allocation Transfer Program Questions and Answers For Canada Customs and Revenue Agency Client Services The Department of Fisheries and Oceans ("DFO") is responsible for issuing fishing licences which include commercial fishing licences to the public. ...