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Creditor # 1, XXXXXXXXXX, and/or Creditor # 2 have not and will not exercise on their security to enable them to vote over XXXXXXXXXX% of the voting shares of Canco # 3. Creditor # 1, XXXXXXXXXX and Creditor # 2 will be providing consents to the proposed transactions detailed hereunder. 10. ... Canco # 3 will agree to pay the above noted fee of $XXXXXXXXXX to Canco # 2 because it expects to earn income on the Canco # 3/ Canco # 12 Loan in excess of such fee. ...

13 February 1990 Ruling HBW4125K3 F- Canada-Korea Income Tax Convention Unedited CRA Tags n/a 19(1) HBW 4125-K3   Jim Wilson   (613) 957-2063 February 13, 1990 Dear 19(1) RE:  24(1) We are writing in reply to your letter dated January 11, 1990, concerning the Canada- Korea Income Tax Convention and the status of the above-noted financial institution.  ... SavageA/DirectorProvincial and International Relations Division Enclosure b.c.c.        ...

21 November 1989 Ruling 58913 F- Charity Unedited CRA Tags 149.1 19(1) File No. 5-8913   R.B. Day   (613) 957-2136 November 21, 1989 19(1) We are writing in reply to your letter of July 12, 1989, and further to your follow-up letter of October 2, 1989, wherein you requested our views regarding the application of section 149.1 of the Income Tax Act where a Charitable organization and /or registered charity (the "registered entity") is a fifty percent partner in a marketing venture in Canada. 24(1) You have posed the following questions with regard to the above- noted registered entity. 24(1) Our Comments Interpretation Bulletin IT-90 defines, in paragraph 2 thereof, a partnership as      "the relation that subsists between persons carrying on business in common with a view to profit. ...

Tax Agreement Unedited CRA Tags n/a 19(1) HBW 4131-U3   Al Watson   (613) 957-2072 January 2, 1990 Dear 19(1) This is to request your concurrence in granting an extension of the sixty-month period of detachment under Article V(2)(a) of the Canada-United States Social Security Agreement in the following case: CANADIAN EMPLOYER: 19(1) EMPLOYEE: The initial period covered by the certificate will conclude on December 31, 1989. ... SavageActing DirectorProvincial and International Relations Division c.c.       ...

14 September 1989 Ruling 58421 F- Renunciation of Resource Expenditures Incurred Prior to the Date of an Agreement in Writing Unedited CRA Tags 66(12.6), 66(12.62), 66(12.64), 66(15) flow-through share 19(1) File No. 5-8421   Frank S. Gillman   (613) 957-8953 September 14, 1989 Dear Sirs: Re:  Agreement in writing Paragraph 66(15)(d.1) of the Income Tax Act (the "Act") This is in reply to your letter dated July 19, 1989, in which you requested our opinion regarding our interpretation of paragraph 66(l5)(d.1) of the Act as it relates to the issue of whether resource expenditures incurred prior to the date on which an agreement is entered into in writing can be renounced pursuant to the flow-through share provisions of the Act. ... The aforesaid subsections may be paraphrased as follows in stating the requirement as to when a principal-business corporation has to incur the various expenses so that they qualify for "flow through" purposes:      "... and, during the period commencing on the day the agreement was entered into and ending 24 months after the end of the month that included that day, the corporation has incurred (the specific expense), the corporation may..., renounce,..., by which those expenses incurred by it during that period... ...

2 October 1989 Ruling 89M10481 F- Oil and Gas Taxation in Canada Course Unedited CRA Tags n/a   October 2, 1989 CALGARY DISTRICT OFFICE HEAD OFFICE Basic Files Section Resource Industries Oil and Gas Industry Studies Section   Jim Gauvreau John Kurrant (613) 957-8953 Subject: Oil and Gas Taxation in Canada Course At your request, I am writing to inform you of the names of those who will be participating on behalf of Rulings in the above-captioned course on October 17th and 18th, 1989.  They are:      John ChanFrank GillmanCarole Gouin-Toussaint Section ChiefResource Industries SectionBilingual Services and ResourceIndustries DivisionRulings Directorate ...

9 January 1990 Ruling F3383 F- IT Bulletin Project #1490 Non-arm's Length Sale of Shares Unedited CRA Tags n/a   January 9, 1990 Mr. ... McColm   957-2068   F-3383   SECRET IT Bulletin Project #1490 Non-Arm's Length Sale of Shares to a Corporation Revision of IT-489 We have reviewed the above draft project and have only the following comment with respect to policy matter, current or pending, that may be relevant to positions taken in the draft. 21(1)(b) B.J. ...

10 November 1989 Ruling 74311 F- Prescribed Form T2061A Unedited CRA Tags 48(1)(a)   November 10, 1989 Non-Resident Taxation Division Specialty Rulings   Directorate Mr. ... We have reviewed the form and offer the following comments. 1.     In our view the election provided in paragraph 48(1)(a) is limited to individuals and we would suggest the first item of the form be adjusted to read as follows:      "For use by a taxpayer who is an individual other than a trust, who ceased at any time in the year to be a resident of Canada, to elect under paragraph 48(1)(a) of the income Tax Act to dispose of property that would be taxable Canadian property if the taxpayer had not been resident in Canada at any time in the year." 2.     Item four requires the addition of a form number. We trust these comments are suitable for your purposes. for Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch ...

27 July 1990 Ruling 901351 F- Canada-Australia Income Tax Convention on Capital Gains Unedited CRA Tags n/a   July 27, 1990 International Audits Division Rulings Directorate   G. ... Calderwood (613) 957-2126 Director   901351     SUBJECT:  24(1) Canada-Australia Income Tax Convention This is in reply to your Memorandum dated June 18, 1990 whereby you requested our opinion as to whether residents of Australia are exempt from Canadian tax liability in respect of capital gains realized on the disposition of taxable Canadian property, particularly shares in the capital stock of a corporation resident in Canada (other than a public corporation), by virtue of the Canada-Australia Income Tax Convention (1980) (the "Treaty"). ...

The issued and outstanding shares of the capital stock of DC, which represent Capital Property to its shareholders, are held as follows: Class A common shares (voting) Shareholder # shares PUC ACB FMV Brother 1 XXXX $ XXXX $ XXXX $ XXXX Corporation 1 XXXX $ XXXX $ XXXX $ XXXX Corporation 2 XXXX $ XXXX $ XXXX $ XXXX Brother 2 XXXX $ XXXX $ XXXX $ XXXX Corporation 3 XXXX $ XXXX $ XXXX $ XXXX Corporation 4 XXXX $ XXXX $ XXXX $ XXXX Series A first preferred shares (voting) Shareholder # shares PUC ACB FMV Brother 1 XXXX $ XXXX $ XXXX $ XXXX Corporation 2 XXXX $ XXXX $ XXXX $ XXXX Brother 2 XXXX $ XXXX $ XXXX $ XXXX Corporation 4 XXXX $ XXXX $ XXXX $ XXXX Series B first preferred shares (non-voting) Shareholder # shares PUC ACB FMV Brother 1 XXXX $ XXXX $ XXXX $ XXXX Brother 2 XXXX $ XXXX $ XXXX $ XXXX Corporation 5 XXXX $ XXXX $ XXXX $ XXXX 4. ...