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Senécal   (613) 957-2074   HBW 4125-3 October 5, 1989 19(1) This letter is in reply to your letter dated July 24, 1989, which was referred to us by the Department of Finance. ... Savage Acting Director Provincial and International Relations Division c.c.      ...

30 October 1989 Ruling 40811 F- Minister's Mail Unedited CRA Tags n/a   October 30, 1989 TO- Toronto District Taxation Office FROM- Technical J.R. ... Tang   (613) 957-9229   File No. 4-0811 SUBJECT: MINISTER'S MAIL 19(1) Our Minister has recently received a request for remission of tax liability, penalty and interest in the amount of 19(1) from 19(1) on behalf of the above noted trust.  ...

21 June 1989 Ruling 58131 F- Partnership Reorganization Unedited CRA Tags 245, 102, 98(3), 85(2), 85(3), 85(1) 19(1) File No. 5-8131   S.J. ... A Canadian partnership (as defined in section 102 of the Act) owns real estate used in an active business and operating assets. 2.     The partnership is wound-up pursuant to subsection 98(3) of the Act. 3.      ...

21 November 1990 Ruling 901323 F- Deductibility of Capital Cost Allowance and Interest Expenses Unedited CRA Tags 18(1), 9(1), 20, 1102(1)(c)   November 21, 1990 VANCOUVER DISTRICT OFFICE HEAD OFFICE   Rulings Directorate   A.Y. Ho   (613) 957-2094 Attention: B.J. Peters Section 198-1-3   901323 SUBJECT:  24(1) We are writing in reply to your memorandum of June 18, 1990 concerning the deductibility of capital cost allowance ("CCA") and interest expenses. ...

The ownership, aggregate ACB, PUC and redemption amount, and percentage of votes associated with the shares of Bco are as follows: Shareholder Class of Shares Number of Shares ACB ($) PUC ($) Redemption Amount ($) Votes (%) Father XXXXXX XXXXXX XXXXXX XXXXXX XXXXXXXX XXXXXX The FMV of the Bco common shares is substantially in excess of their ACB to their holder. 17. ... The ownership, aggregate ACB, PUC and redemption amount, and percentage of votes associated with the shares of Cco are as follows: Shareholder Class of Shares Number of Shares ACB ($) PUC ($) Redemption Amount ($) Votes (%) Sibling1 XXXXXX XXXXXX XXXXXX XXXXXX XXXXXXXX XXXXXX Trust1 XXXXXX XXXXXX XXXXXX XXXXXX XXXXXXXX XXXXXX The FMV of the Cco common shares is substantially in excess of their ACB to their holder. 19. ... The ownership, aggregate ACB, PUC and redemption amount, and percentage of votes associated with the shares of Hco are as follows: Shareholder Class of Shares Number of Shares ACB ($) PUC ($) Redemption Amount ($) Votes (%) Aco XXXXXXX XXXXXX XXXXXX XXXXXX XXXXXXXX XXXXXX XXXXXXX XXXXXXX XXXXXX XXXXXX XXXXXX XXXXXXXX XXXXXX The FMV of the XXXXXXXXXX Shares of Hco is substantially in excess of their ACB to their holder. 27. ...

21 June 1989 Ruling 57721 F- Acquisition of Control of Corporation Unedited CRA Tags 249(4)   19(1) File No. 5-7721   Firoz Ahmed   (613) 957-2092 June 21, 1989 Dear Sirs: Re:  Subsection 249(4) of the Income Tax Act (Canada) (the "Act") This is in response to your letter of March 17, 1989 in which you requested our views as to the application of subsection 249(4) of the Act in the context of the situation described below. ...

20 November 1989 Ruling 58623 F- Tax Shelter- Meaning of Prescribed Benefit Unedited CRA Tags 237.1(1), 231(6)(a)(iii)   19(1) File No. 5-8623   C. Tremblay   (613) 957-2095 November 20, 1989 Dear Sirs: Re:  Prescribed Benefit for the Purposes of Subsection 237.1(1) of the Income Tax Act (the "Act") This is in reply to your letter of August 31, 1989, concerning the interpretation of a prescribed benefit as set out in subparagraph 231(6)(a)(iii) of the Draft Income Tax Regulations issued June 8, 1989 (the "Draft Regulations").  ...

DEFINITIONS In this letter, the following terms have the meanings specified below: • "Acquiror" has the meaning assigned in the definition of "specified corporation" in subsection 55(1); • "Act" means the Income Tax Act, R.S.C. 1985 (5th Supp.) c. 1, as amended to the date hereof, and unless otherwise stated, every reference herein to a part, section, subsection, paragraph, subparagraph or clause is a reference to the relevant provision of the Act; • "Act 2" means the Business Corporations Act (XXXXXXXXXX); • "Act 3" means the Business Corporations Act (XXXXXXXXXX); • "adjusted cost base" has the meaning assigned by section 54; • "agreed amount" in respect of a property means the amount that the transferor and the transferee of the property have agreed upon in an election under subsection 85(1); • "Aggregate DC Redemption Amount" has the meaning assigned by Paragraph 47; • "Aggregate Spinco Redemption Amount" has the meaning assigned by Paragraph 39; • "arm's length" has the meaning assigned by section 251; • "Business 1" means the business of Opco 2 and Opco 3 of XXXXXXXXXX; • "Business 2" means the business of XXXXXXXXXX; • "capital property" has the meaning assigned by section 54; • "Capital Reorganization" means the exchange of each DC Common Share for one DC New Common Share and one DC Special Share as described in Paragraph 48; • "cost amount" has the meaning assigned by subsection 248(1); • "DC" has the meaning assigned in Paragraph 1; • "DC Common Shares" means the common shares that DC is currently authorized to issue as described in Paragraph 6; • "DC New Common Shares" means the new common shares that DC will be authorized to issue as described in Paragraph 47; • "DC Redemption Amount" has the meaning assigned by Paragraph 47; • "DC Redemption Note" means the demand promissory note with a principal amount equal to the Aggregate DC Redemption Amount to be issued by DC in favour of Spinco as described in Paragraph 61; • "DC Shares" means the DC New Common Shares and the DC Special Shares collectively; • "DC Shareholders" means all of the holders of DC Common Shares immediately before the Effective Date; • "DC Special Shares" means the special shares that DC will be authorized to issue as described in Paragraph 47; • "DC Stock Options" has the meaning assigned by Paragraph 8; • "Dissenting Shareholder" means a DC Shareholder who exercises the right to dissent under the Plan of Arrangement; • "distribution" has the meaning assigned by subsection 55(1); • "Effective Date" means the date on which the Plan of Arrangement becomes effective, which is currently pending approval of this ruling; • "fair market value" means the highest price available in an open and unrestricted market between informed prudent parties acting at arm's length and under no compulsion to act, expressed in terms of cash; • "Leaseco" has the meaning assigned by Paragraph 24; • "New Opco" has the meaning assigned by Paragraph 44; • "New Opco Common Shares" has the meaning assigned by Paragraph 44; • "Old Opco" has the meaning assigned by Paragraph 19; • "Old Opco Receivable" has the meaning assigned by Paragraph 23; • "Opco 2" means XXXXXXXXXX.; • "Opco 3" means XXXXXXXXXX.; • "paid-up capital" has the meaning assigned by subsection 89(1); • "Paragraph" refers to a numbered paragraph in this advance income tax ruling; • "Participant" means a DC Shareholder other than a Dissenting Shareholder; • "Plan of Arrangement" means the plan of arrangement under Act 2 to effect the divisive reorganization described in the "Proposed Transactions"; • "Proposed Amendments" means the amendments that are proposed to be introduced by Bill C-10, Income Tax Amendments Act, 2006; • "Proposed Transactions" means the transactions described in Paragraphs 43 to 68, inclusive; • "public corporation" has the meaning assigned to that term by subsection 89(1); • "related person" has the meaning assigned by subsection 251(2); • "restricted financial institution" has the meaning assigned by subsection 248(1); • "Retained DC Assets" means all assets of DC owned by DC immediately before the Spin-off other than the New Opco Common Shares; • "Share Option Plan" means the stock-based compensation plan pursuant to which the DC Stock Options were granted as described in paragraph 8; • "specified financial institution" has the meaning assigned by subsection 248(1); • "Spinco" means the newly incorporated corporation incorporated for the purposes of completing the Plan of Arrangement as described in Paragraph 38; • "Spinco Common Shares" means the common shares which Spinco is authorized to issue as described in Paragraph 39; • "Spinco Redemption Amount" has the meaning assigned by Paragraph 39; • "Spinco Redemption Note" means the demand promissory note with a principal amount equal to the Aggregate Spinco Redemption Amount issued by Spinco in favour of DC as described in Paragraph 60; • "Spinco Shares" means the Spinco Common Shares and Spinco Special Shares, collectively; • "Spinco Special Shares" means the special shares that Spinco is authorized to issue as described in Paragraph 39; • "Spin-off" means the transfer by DC to Spinco of the New Opco Common Shares as described in Paragraph 54; • "stated capital" has the meaning assigned by Act 2; • "Stock Exchange 1" has the meaning assigned by Paragraph 1; • "Stock Exchange 2" has the meaning assigned by Paragraph 1; • "taxable Canadian corporation" has the meaning assigned to that term by subsection 89(1); • "taxable dividend" has the meaning assigned by subsection 89(1); and • "Transfer Percentage" means the number, expressed as a percentage, which the net fair market value of the New Opco Common Shares represents of the fair market value of all of the net assets of DC, determined immediately before the Spin-off. ... (operating as "XXXXXXXXXX ") ("Opco 4"), and XXXXXXXXXX. ... Over XXXXXXXXXX % of the shares voted were voted in favour of the Plan of Arrangement. ...

Le prix de base rajusté et le capital versé de ces actions sont de XXXXXXXXXX $ alors que la juste valeur marchande est de XXXXXXXXXX $. 7. ... Le prix de base rajusté et le capital versé de ces actions sont de XXXXXXXXXX $ alors que la juste valeur marchande est de XXXXXXXXXX $. 10. ... Gestion A recevra en échange XXXXXXXXXX actions de catégorie «E» d’Opérante ayant un capital versé de XXXXXXXXXX $ chacune, rachetables avec une prime deXXXXXXXXXX $. ...

L'excédent, d'un montant de XXXXXXXXXX $, a été comptabilisé comme suit: XXXXXXXXXX $ à titre de solde de prix d'achat à payer, XXXXXXXXXX $ au surplus d'apport comptable, et XXXXXXXXXX $ au CCAÉP. Du montant de XXXXXXXXXX $ attribué au CCAÉP, les montants de XXXXXXXXXX $ et XXXXXXXXXX $ ont été attribués respectivement au CCAÉP des actions privilégiées de catégorie XXXXXXXXXX (XXXXXXXXXX actions avec une valeur nominale de XXXXXXXXXX $ par action) et au CCAÉP des actions ordinaires (XXXXXXXXXX actions avec une valeur nominale de XXXXXXXXXX $ par action). ... L'allocation du prix payé pour une unité (XXXXXXXXXX $), entre le prix payé pour une action ordinaire de GESTCO (XXXXXXXXXX $) et le prix payé pour un demi BS2 (XXXXXXXXXX $), était raisonnable. 19. ...