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.), as amended to the date hereof; (d) "active business" has the meaning assigned by subsection 95(1) of the Act; (e) "arm's length" has the meaning assigned by section 251 of the Act; (f) "B Co" means XXXXXXXXXX as described in Paragraph 9; (g) "B Co Shares" means shares of B Co as described in Paragraph 12; (h) "C Co Shares" means shares of XXXXXXXXXX as described in Paragraph 12; (i) "CBCA" means the Canada Business Corporations Act; (j) "CRA" means the Canada Revenue Agency; (k) "C Co" means XXXXXXXXXX as described in Paragraph 7; (l) "D Co" means XXXXXXXXXX as described in Paragraph 10; (m) "D Co Shares" means the shares of D Co as described in Paragraph 12; (n) "E Co" means XXXXXXXXXX as described in Paragraph 9; (o) "E Co Leasing" means a subsidiary of a XXXXXXXXXX holding company directly held by E Co as described in Paragraph 9; (p) "fair market value" means the amount at which property would exchange hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of the relevant facts; (q) "H Co " means XXXXXXXXXX as described in Paragraph 10; (r) "I Co" means XXXXXXXXXX as described in Paragraph 9; (s) "IF Co" means XXXXXXXXXX. as described in Paragraph 8; (t) "LP" means XXXXXXXXXX and Company LP as described in Paragraph 8; (u) "New LP" means a new limited partnership as described in Paragraph 20; (v) "Note" means a promissory note issued by A Co to W Co as described in Paragraph 15; (w) "paid-up capital" has the meaning assigned by subsection 89(1) of the Act; (x) "Paragraph" means a numbered paragraph in this advance income tax ruling; (y) "Preference Shares" means voting preference shares of A Co as described in Paragraph 6; (z) "principal amount" has the meaning assigned by subsection 248(1) of the Act; (aa) "Proposed Transactions" means the proposed transactions described in Paragraphs 22 to 29; (bb) "Regulations" means Income Tax Regulations, Consolidated Regulations of Canada, Chapter 945 as amended to the date hereof; (cc) "Reinvestment Agreement" means an agreement between T Co, A Co and W Co as described in Paragraph 18; (dd) "related persons" has the meaning assigned by subsection 251(2) of the Act; (ee) "Share Transfer Agreement" means a share transfer agreement entered into by A Co and W Co as described in Paragraph 12; (ff) "taxable Canadian corporation" has the meaning assigned by subsection 89(1) of the Act; (gg) "T Co" means XXXXXXXXXX as described in Paragraph 11; (hh) "third parties" means persons who act at arm's length with the X Group; (ii) "Transferred Shares" has the meaning described in Paragraph 12; (jj) "Treaty" means the Canada-United States Income Tax Convention; (kk) "W Co" means XXXXXXXXXX as described in Paragraph 2; (ll) "X Co" means XXXXXXXXXX as described in Paragraph 1; (mm) "X Group" means X Co and entities related to X Co; (nn) "Z Co" means XXXXXXXXXX, as described in Paragraph 6. ... On XXXXXXXXXX, A Co and W Co entered into a share transfer agreement (the "Share Transfer Agreement") pursuant to which A Co agreed to acquire from W Co, and W Co agreed to transfer to A Co, XXXXXXXXXX% of the shares of C Co (the "C Co Shares"), XXXXXXXXXX % of the shares of B Co (the "B Co Shares"), and XXXXXXXXXX% of the shares of D Co (the "D Co Shares") (collectively, the "Transferred Shares"). ... A Co, as limited partner, and IF Co, as general partner, formed a limited partnership in XXXXXXXXXX, New LP, under " XXXXXXXXXX " on XXXXXXXXXX. 21. ...

XXXXXXXXXX 2004-006815 XXXXXXXXXX, 2004 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX (the "Corporation") (Account # XXXXXXXXXX) XXXXXXXXXX. (the "Employer") (Account # XXXXXXXXXX) This is in reply to your letter of XXXXXXXXXX, in which you requested an advance income tax ruling on behalf of the Corporation, the Employer and the Participants. ... The commission rates range from XXXXXXXXXX % to XXXXXXXXXX % of the XXXXXXXXXX gross production, with the commission rates increasing as the XXXXXXXXXX level of gross production increases as set out in the following table. ...

XXXXXXXXXX Les dettes d'OPCO s'élevaient à XXXXXXXXXX. 5.Le capital-actions autorisé d'OPCO se compose de XXXXXXXXXX actions ordinaires ayant une valeur nominale de XXXXXXXXXX $ chacune et de XXXXXXXXXX actions privilégiées d'une valeur nominale de XXXXXXXXXX $ chacune, à dividende non cumulatif de XXXXXXXXXX %, et rachetables à leur valeur nominale. 6.Le capital-actions émis et en circulation d'OPCO se compose de XXXXXXXXXX actions ordinaires possédées par les actionnaires suivants: Nombre Actionnaires d'actions % GESCO A XXXXXXXXXX XXXXXXXXXX GESCO B XXXXXXXXXX XXXXXXXXXX GESCO C XXXXXXXXXX XXXXXXXXXX GESCO D XXXXXXXXXX XXXXXXXXXX Total XXXXXXXXXX XXXXXXXXXX Le capital versé (au sens du paragraphe 89(1) de la Loi) des actions ordinaires est de XXXXXXXXXX $. 7.XXXXXXXXXX. ... Des dividendes de XXXXXXXXXX $ ont déjà été versés par OPCO depuis le XXXXXXXXXX. ... GESCO A souscrira à XXXXXXXXXX actions ordinaires de catégorie XXXXXXXXXX du trésor de Filco pour un montant de XXXXXXXXXX $. ...

(d)     A Co and B Co are two arm's-length corporate shareholders of Opco, each of whom owns 50% of the shares of Opco.  ... (e)     Can a person be a member of a "group" controlling a corporation if that individual owns no shares of the corporation? ... (d)     If A Co and C Co act in concert to control Opco, they would be considered to be a group of persons that had acquired control of Opco. ...

.- Adverse Decision of Tax Court of Canada Unedited CRA Tags n/a   February 12, 1990 To: Head Office From: Technical Interpretations Appeals Branch Division G.D. ... Simmonds & Sons Ltd.- Adverse Decision of Tax Court of Canada We are replying to J. ...

The Ruling is revised as follows: 1) In the Definitions, the following definition is added: (mm) "Make-Whole Amount" means, in the case of any voluntary prepayment of the Term Loan B, the excess, if any, of (a) the aggregate present value as of the date of such prepayment of (i) each dollar of principal being prepaid, (ii) the amount of interest (exclusive of interest accrued to the date of prepayment) that would have been payable in respect of such dollar if such prepayment had not been made, calculated from the date of such prepayment through and including the XXXXXXXXXX-year anniversary of the Term Loan B issue date, and (iii) a premium equal to XXXXXXXXXX % of the amount of such principal that would have been payable on the XXXXXXXXXX-year anniversary of the issue date of Term Loan B if such prepayment had not been made, over (b) the aggregate principal amount of the Term Loan B being prepaid. 2) The date "...XXXXXXXXXX... ... The Term Loan B prepayment premium (the "Term Loan B Prepayment Premium")- the Make-Whole Amount, if the prepayment is made in the first two years, XXXXXXXXX % of the prepayment if the prepayment is made in the third year, XXXXXXXXX % of the prepayment if the prepayment is made in the fourth year and XXXXXXXXX, thereafter. ...

Position Adoptée: Pour des raisons de politique fiscale le législateur a décidé de ne pas accorder d'allégement fiscal lorsqu'un employé achète un ordinateur Raisons POUR POSITION ADOPTÉE: Raison de politique fiscale et paragraphe 8(2) de la Loi Conférence annuelle des conseillers techniques Table ronde Question 25 QUESTION # 25 Un employé qui est un vendeur à commissions peut déduire, notamment, des frais relativement à la location d'un ordinateur si les conditions énoncées aux sous-alinéas 8(1)f)(i) à (iv) de la Loi sont rencontrées. ...

2011 Ruling 2010-0391551R3- Related Foreign Entity Financing Unedited CRA Tags 15(1), 15(2), 15(2.2), 15(9), 17(1), 17(2), 80.4(2), 91(1), 91(4), 212(2), 214(3) & 245 Principal Issues: Whether a loan from a controlled foreign affiliate to a related non-resident entity will trigger the application of subsection 15(2) and Part XIII. ... XXXXXXXXXX 2010-039155 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 2011 Dear XXXXXXXXXX: Re: XXXXXXXXXX ("Canco") & XXXXXXXXXX We are writing in response to your request dated XXXXXXXXXX for an advance income tax ruling on behalf of the above noted taxpayers. ... Yours truly, for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

XXXXXXXXXX 2004-009868 XXXXXXXXXX, 2004 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request- XXXXXXXXXX ("Trust XXXXXXXXXX ") This is in reply to your letter of XXXXXXXXXX, wherein you requested an advance income tax ruling with respect to the tax treatment of benefits paid from the above-noted long-term disability plan. ... At the time of collective bargaining between the XXXXXXXXXX and the XXXXXXXXXX in XXXXXXXXXX, LTD Benefits were provided to XXXXXXXXXX Members from a trust fund established in XXXXXXXXXX and known as XXXXXXXXXX (hereafter, "Trust XXXXXXXXXX "). 11. ... (b) The monthly benefit payable to the disabled XXXXXXXXXX Member is the greater of (i) XXXXXXXXXX% of pre-disability monthly earnings up to a specified amount ($XXXXXXXXXX for disabilities that occur in XXXXXXXXXX), and XXXXXXXXXX % of pre-disability monthly earnings in excess of this amount, and (ii) XXXXXXXXXX% of pre-disability monthly earnings. ...

XXXXXXXXXX 2013-047876 XXXXXXXXXX, 2013 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling – XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX, in which you requested an advance income tax ruling on behalf of the above-named taxpayer. ... The FN2 is one of the listed bands that are authorized pursuant to the Indian Band Revenue Moneys Order, # SOR/90-297, to control, manage, and expend in whole their revenue money under subsection 69(1) of the Indian Act. 9. ... The programs are run by XXXXXXXXXX employed by the FN2, whose duties include administering non-insured health benefits for the FN2 members and arranging for transportation for the FN2 members in need of health care services away from the community.) d) Landfill e) Playgrounds f) Tourism facilities (park with campsites) g) Recreation centre/community complex h) Ice rink (outdoor rink located at XXXXXXXXXX) i) XXXXXXXXXX / water infrastructure 20. ...