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XXXXXXXXXX procédera à la déclaration d'un dividende de XXXXXXXXXX $. Ce dividende sera payé par l'émission d'un billet à demande sans intérêt au montant de XXXXXXXXXX $ et d'un montant payé comptant au montant de XXXXXXXXXX $. ... Cette vente résultera en un gain en capital au montant de XXXXXXXXXX $ correspondant à la différence entre le prix de vente de XXXXXXXXXX $ et le prix de base rajusté de XXXXXXXXXX $. ...

Au paragraphe 16 de la Décision, les montants de XXXXXXXXXX $ et de XXXXXXXXXX $ et le taux de XXXXXXXXXX% sont remplacés respectivement par les montants de XXXXXXXXXX $ et de XXXXXXXXXX $ et le taux de XXXXXXXXXX%. ... Au paragraphe 19 de la Décision, le montant de XXXXXXXXXX $ est remplacé par le montant de XXXXXXXXXX $. 10. Au paragraphe A de la Décision, à la 3e ligne, les mots " telle que décrite au paragraphe 9 de la présente " sont remplacés par les mots " telle que décrite aux paragraphes 9 et 10 de la présente ". ...

DEFINITIONS In this letter, all references to monetary amounts are in Canadian dollars and the following terms or expressions have the meaning specified: * "A Co" means XXXXXXXXXX; * "Act" means the Income Tax Act, R.S.C. 1985 (5th Supp.) c.1, as amended from time to time and consolidated to the date of this letter and, unless otherwise expressly stated, every reference herein to a part, section or subsection, paragraph or subparagraph and clause or subclause is a reference to the relevant provision in the Act, and the Income Tax Regulations thereunder are referred to as the "Regulations"; * "adjusted cost base" ("ACB") has the meaning assigned by section 54; * "agreed amount" means the amount agreed on in respect of a property in an election filed pursuant to subsection 85(1); * "B Co" means XXXXXXXXXX; * "BCA" means the XXXXXXXXXX; * "BN" means the tax identification number assigned by the CRA to the particular entity; * "Butterfly 1" means the distribution of all of the property of DC1 to A Co, B Co and C Co, which was undertaken pursuant to the transactions set out in paragraphs 80 to 90 of the Original Ruling, all of which have been completed, except for certain matters related to the dissolution of DC1 as set out in the proposed transaction described in paragraph 90 of the Original Ruling; * "Butterfly 2" means the distribution of all of the property of DC2 to TC1-Sub, TC2-Sub, TC3-Sub, and TC4-Sub, which was undertaken pursuant to the transactions set out in paragraphs 93 to 109 of the Original Ruling, all of which have been completed, except for certain matters related to the dissolution of the Transferee2-Subs and DC1 as set out in the proposed transactions described in paragraphs 104, 107, 108 and 109 of the Original Ruling; * "C Co" means XXXXXXXXXX; * "Canadian-controlled private corporation" ("CCPC") has the meaning assigned by subsection 125(7); * "capital property" has the meaning assigned by section 54; * "XXXXXXXXXX Co" means XXXXXXXXXX.; * "CRA" means the Canada Revenue Agency; * "DC1" means XXXXXXXXXX.; * "DC2" means XXXXXXXXXX; * "eligible property" has the meaning assigned by subsection 85(1.1); * "fair market value" ("FMV") means the highest price available in an open and unrestricted market, between informed, prudent parties, acting at arm's length and with no compulsion to act, expressed in terms of cash; * "Numberco" means XXXXXXXXXX, which is a taxable Canadian corporation and a CCPC; * "Original Ruling" means advance tax ruling 2006-020398, which was issued to DC1 and DC2 on XXXXXXXXXX, 2006; * "paid-up capital" ("PUC") has the meaning assigned by subsection 89(1); * "Paragraph" refers to a numbered paragraph in this advance income tax ruling; * "proceeds of disposition" has the meaning assigned by section 54; * "Proposed Transactions" means the transactions described in Paragraphs 14 to 23; * "Real Co" means XXXXXXXXXX * "Real Co Promissory Note(s)" means one or more of the demand promissory notes payable by Real Co, as described in Paragraph 15, either singularly or collectively; * "Real Co Properties" means Real Co's direct ownership interest in one revenue-producing commercial real property, and Real Co's indirect interest, through XXXXXXXXXX separate tenancy in common arrangements and one partnership, in certain revenue-producing industrial and commercial real properties and numerous parcels of land held for future development as revenue-producing industrial and commercial real properties, together with ancillary deposits, accounts receivable, and rights arising from prepaid expenses; * "Real Co Property" means any one of the seven "Real Co Properties"; * "Real-Subco1" means the taxable Canadian corporation incorporated by Real Co, as described in Paragraph 10; * "Real-Subco2" means the taxable Canadian corporation incorporated by Real Co, as described in Paragraph 10; * "Real-Subco3" means the taxable Canadian corporation incorporated by Real Co, as described in Paragraph 10; * "Real-Subco4" means the taxable Canadian corporation incorporated by Real Co, as described in Paragraph 10; * "Real-Subco5" means the taxable Canadian corporation incorporated by Real Co, as described in Paragraph 10; * "Real-Subco6" means the taxable Canadian corporation incorporated by Real Co, as described in Paragraph 10; * "Real-Subco7" means the taxable Canadian corporation incorporated by Real Co, as described in Paragraph 10; * "Real-Subco(s)" means Real-Subco1, Real-Subco2, Real-Subco3, Real-Subco4, Real-Subco5, Real-Subco6, and Real-Subco7, either singularly or collectively; * "related person" has the meaning assigned by section 251; * "Second Ruling" means advance tax ruling 2007-0232261R3, which was issued to Real Co and XXXXXXXXXX Co on XXXXXXXXXX, 2007; * "series of transactions or events" includes the transactions or events referred to in subsection 248(10); * "stated capital" has the meaning assigned by the BCA; * "taxable Canadian corporation" has the meaning assigned by subsection 89(1); * "TC1" means XXXXXXXXXX., which is a taxable Canadian corporation and a CCPC; * "TC1-Sub" means XXXXXXXXXX., which is a taxable Canadian corporation and a CCPC; * "TC2" means XXXXXXXXXX., which is a taxable Canadian corporation and a CCPC; * "TC2-Sub" means XXXXXXXXXX., which is a taxable Canadian corporation and a CCPC; * "TC3" means XXXXXXXXXX., which is a taxable Canadian corporation and a CCPC; * "TC3 Promissory Note(s)" means one or more of the demand promissory notes payable by TC3, as described in Paragraph 19, either singularly or collectively; * "TC3 Properties" means TC3's indirect interest, through four separate tenancy in common arrangements, in certain revenue-producing industrial and commercial real properties and numerous parcels of land held for future development as revenue-producing industrial and commercial real properties, together with ancillary deposits, accounts receivable, and rights arising from prepaid expenses; * "TC3 Property" means any one of the four "TC3 Properties"; * "TC3-Sub" means XXXXXXXXXX., which is a taxable Canadian corporation and a CCPC; * "TC3-Subco1" means the taxable Canadian corporation incorporated by TC3, as described in Paragraph 12; * "TC3-Subco2" means the taxable Canadian corporation incorporated by TC3, as described in Paragraph 12; * "TC3-Subco3" means the taxable Canadian corporation incorporated by TC3, as described in Paragraph 12; * "TC3-Subco4" means the taxable Canadian corporation incorporated by TC3, as described in Paragraph 12; * "TC3-Subco(s)" means TC3-Subco1, TC3-Subco2, TC3-Subco3, and TC4-Subco4, either singularly or collectively; * "TC4" means XXXXXXXXXX, which is a taxable Canadian corporation and a CCPC; * "TC4-Sub" means XXXXXXXXXX., which is a taxable Canadian corporation and a CCPC; and * "Transferee2-Sub(s)" means TC1-Sub, TC2-Sub, TC3-Sub and TC4-Sub, either singularly or collectively. ... The Common Shares held by A Co represent XXXXXXXXXX % of the issued and outstanding Common Shares of Real Co. ... The Common Shares held by B Co represent XXXXXXXXXX % of the issued and outstanding Common Shares of Real Co. ...

19 February 1990 Ruling 58021- Exonération de gains en capital- action admissible de petite entreprise- corporation exploitant une petite entreprise Unedited CRA Tags 110.6(1) action admissible de petite entreprise, 248(1) société exploitant une petite entreprise 19(1) File No. 5-8021   A. ... En résumé, la situation que vous décrivez est la suivante.-      La Cie A est une filiale détenue à 100% par Cie XYZ.  Cie A utilise la totalité de son actif dans une entreprise exploitée activement au Canada à l'exception de l'avance décrite ci-dessous.-     La Cie A a consenti des avances à la corporation de portefeuille Cie XYZ.  ...

22 August 1990 Ruling 9016033 F- Remuneration Paid to Spouse Unedited CRA Tags 18(1)(a), 67 19(1) 3-901603   R.D. Mundell   (613) 957-2139   EACC9282 August 22, 1990 Dear Sir: Re: Remuneration Paid to Spouse This will reply to your letter of July 13, 1990 requesting an advance income tax ruling concerning the proposed payment of "remuneration" to your wife. 24(1) Your concern is whether such a payment would be deductible by you for income tax purposes. ...

There are, prior to the implementation of the Proposed Transactions, XXXXXXXXXX, issued and outstanding Class A shares, owned as follows: Shareholder # Shares % Ownership Sibling A XXXXXXXXX XXXXXXXXX % Spouse A XXXXXXXXX XXXXXXXXX % Child A1 XXXXXXXXX XXXXXXXXX % Child A2 XXXXXXXXX XXXXXXXXX % Sibling B XXXXXXXXX XXXXXXXXX % Spouse B XXXXXXXXX XXXXXXXXX % Trust B XXXXXXXXX XXXXXXXXX % Transferee A XXXXXXXXX XXXXXXXXX % DC1 XXXXXXXXX XXXXXXXXX % FC1 XXXXXXXXX XXXXXXXXX % FC2 XXXXXXXXX XXXXXXXXX % Various Arm's Length Third Parties XXXXXXXXX XXXXXXXXX % The FamilyCo common shares are held by each of the above-mentioned shareholders as capital property. 3. ... The following table outlines the issued and outstanding shares: Shareholder # Shares ACB PUC Sibling A XXXXX common shares $ XXXXX $ XXXXX XXXXX Class B Special shares $ XXXXX $ XXXXX Sibling B XXXXX common shares $ XXXXX $ XXXXX XXXXX Class B Special shares $ XXXXX $ XXXXX The FC1 Class B Special shares and common shares are held by each of the above-mentioned shareholders as capital property. ... The following table outlines the issued and outstanding shares: Shareholder # Shares ACB PUC Sibling A XXXX Class B Special shares $ XXXX $ XXXX Sibling B XXXX Class B Special shares $ XXXX $ XXXX FC1 XXXX Common shares $ XXXX $ XXXX The FC2 Class B Special shares and common shares are held by each of the above-mentioned shareholders as capital property. ...

McKenzie Technical Interpretations A/Director Division   Esta Mikhail   (613) 952 3606   4-0833 19(1) The Honourable Michael H. ...

DC's issued share capital is held as follows: SHAREHOLDER NUMBER AND CLASS OF SHARES PUC ACB Estate XXXXX Class A PS $XXXXXX $XXXXX XXXXX Class C PS $ XXXXX $ XXXXX XXXXX Class E PS $ XXXXX $ XXXXX B XXXXX Common Shares $ XXXXX $ XXXXX XXXXX Class B PS $ XXXXX $ XXXXX XXXXX Class D PS $ XXXXX $ XXXXX A XXXXX Common Shares $ XXXXX $ XXXXX XXXXX Class B PS $ XXXXX $ XXXXX XXXXX Class D PS $ XXXXX $ XXXXX 10. ... Immediately before undertaking the Proposed Transactions, DC will also own XXXXXXXXXX % of the shares in CCo, which are being held as Capital Property. 15. ... Immediately following the issuance of the Class C Special Shares described in paragraph 34 above, DC will own more than XXXXXXXXXX % of the issued share capital of each of ACo and BCo which have full voting rights under all circumstances and which have a FMV which exceeds more than XXXXXXXXXX % of the FMV of all the issued shares of the capital stock of each of ACo and BCo. ...

5 April 1990 Ruling 59291 F- Trust Designations with respect to Beneficiary Unedited CRA Tags 104(13.1), 108(1) testamentary trust, 108(1) cost amount, 122(2) 19(1) File No. 5-9291   D.S. Delorey   (613) 957-3495 April 5, 1990 Dear Sirs: Re:  Subsection 104(13.1) Designations This is in reply to your letter of December 21, 1989 and further to our telephone conversation (Delorey  19(1)  on March 29, 1990 concerning designations by a trust under subsection 104(13.1) of the Income Tax Act (the "Act"). Your particular concern is with respect to the situation where a trust makes a subsection 104(13.1) designation and the beneficiary pays the trust's resulting tax liability by either (a)     reimbursing the trustee, (b)     giving the trustee a cheque made payable to the Receiver General, or (c)     receiving a net amount from the trustee; i.e., an amount equal to the beneficiary's share of the trust's income less his share of the taxes. ...

31 August 1989 Ruling 89M08403 F- Remission of Tax Unedited CRA Tags n/a   August 31, 1989 LONDON DISTRICT OFFICE Technical   Interpretations Division Mr. ... In particular, we would appreciate your comments on the following matters: 1. 2.     24(1) 3.      ...