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"concept of source of production in resource allowance provisions is broader than in legislation where "development" must be distinguished from "production" April 13, 2000 Calgary Tax Services Office Resource Industries Section Denise Dalphy Attention: Bharat Patel (613) 957-9231 Oil & Gas Specialist 991848 1999-001191 Costs of Tangible Capital Property This is in reply to you facsimile transmission of July 7, 1999 concerning submissions dated June 2 and 18, 1999 that you received from XXXXXXXXXX. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayers 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 taxpayers or a related person; (iii) under objection by the taxpayers 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 judgment has been issued, the time limit for appeal to a higher court has not expired. ...

XXXXXXXXXX 3-971404 / 3-990693 Attention: XXXXXXXXXX XXXXXXXXXX, 1999 Dear Sirs/Madams: Re: Advance Income Tax Rulings XXXXXXXXXX We are writing in reply to your letter of XXXXXXXXXX, wherein you requested an advance income tax ruling under the Income Tax Act (Canada) (the "Act") on behalf of XXXXXXXXXX in respect to the facts and proposed transactions described below. ...

These rulings are given subject to the limitations and qualifications set forth in Canada Customs & Revenue Agency (the "Agency") Information Circular 70-6R3 dated December 30, 1996, and are binding upon the Agency provided the Plan is implemented on or before XXXXXXXXXX. ...

The more significant marketable securities are: (a) an approximately XXXXXXXXXX% interest in the common shares of the XXXXXXXXXX; (b) an approximately XXXXXXXXXX% interest in the common shares of XXXXXXXXXX; (c) approximately XXXXXXXXXX% of the XXXXXXXXXX shares and XXXXXXXXXX% of the XXXXXXXXXX shares of XXXXXXXXXX; and (d) approximately XXXXXXXXXX% of the XXXXXXXXXX common shares and XXXXXXXXXX% of the XXXXXXXXXX " shares of XXXXXXXXXX. ...

He will be a shareholder and director of Newco and will establish a corporation ("XXXXXXXXXX ") that will become a Contracting Company. 33. ...

ADMINISRATIVE MATTERS: The taxpayers' names and Social Insurance Numbers / Business Numbers are as follows: XXXXXXXXXX /Mother XXXXXXXXXX XXXXXXXXXX /Child 1 XXXXXXXXXX XXXXXXXXXX GROUP Related and Associated Companies XXXXXXXXXX /Aco XXXXXXXXXX XXXXXXXXXX /Bco XXXXXXXXXX XXXXXXXXXX. ...

., B Co. and other persons related to A Co. for purposes of the Act.have generally participated in approximately XXXXXXXXXX % of the funding for XXXXXXXXXX joint venture program. 7. ...

Each of the following corporations is a Canadian corporation, TCC and private corporation: Corporate Name Date incorporated Account # XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX All the above companies were incorporated in XXXXXXXXXX and file their corporate income tax returns at the XXXXXXXXXX Taxation Centre. ...

In determining the amount of income from an office or employment, paragraph 6(1)(a) of the Income Tax Act (the "Act") requires the inclusion of the value of any kind of benefits received or enjoyed "... in respect of, in the course of, or by virtue of an office or employment... ...