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14 June 2002 Internal T.I. 2001-0096897- SUPPLEMENTARY EMPLOYEE RETIREMENT PLAN Unedited CRA Tags 248(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... June 14, 2002 TORONTO CENTRE TSO HEADQUARTERS Provis Wong P. Kohnen, CMA Section 443-2-5 (613) 957-2093 2001-009689 Supplementary Employee Retirement Plan This is in reply to your submission of August 14, 2001, and the submission from your client, as well as our subsequent telephone conversations (Kohnen/Wong) in which you requested our views regarding the appropriate taxation status of the Supplementary Employee Retirement Plan ("SERP") sponsored by the taxpayer client. ... & 2.) In our document 9619803 dated XXXXXXXXXX, 1996, which the taxpayer's representative has referred to, we provided rulings in respect of a supplemental retirement arrangement ("SRA") that was similar in design to the plan in question here. ...

14 February 2002 Internal T.I. 2002-0116647- TUITION Unedited CRA Tags 118.5 118.6 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Reasons: 118.5 and 118.6 February 14, 2002 IRPPD Validation Section HEADQUARTERS Assessment and Collections Branch Denise Dalphy, LL.B. 25 McArthur Road, Tower C, Room 510 (613) 941-1722 Attention:Ms. Carol Johnston 2002-011664 XXXXXXXXXX Tuition and Education Credits This is in response to your facsimile transmission of January 3, 2002 wherein you enquired whether the above-referenced entity is an educational institution providing courses at a post-secondary level, as this concept is employed in sections 118.5 and 118.6 of the Income Tax Act (the "Act"). ...

21 August 2002 Internal T.I. 2002-0138617- LIFE INSURANCE FOREIGN CURRENCY SWAPS Unedited CRA Tags 138(2) 138(9) 18(1)(c) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... August 21, 2002 Income Tax Appeals Division Income Tax Rulings John Crowley Directorate Manager K. ... Comments We maintain the view expressed in our document dated September 13, 2000 (# 2000-0042885) that a derivative agreement such as a swap or forward contract is a contractual arrangement separate from any associated asset or liability for which it may be designed to hedge. ...

5 July 2002 Internal T.I. 2001-0112757- Income from Custom Processing Unedited CRA Tags Reg 1104(5) 1104(5.1) 1100(1)(y) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... July 5, 2002 Québec Tax Services Office HEADQUARTERS Richard Cloutier Reorganizations and Mining Industry Specialist Resources Division David Shugar (613) 957-2134 2001-011275 Income from Custom Processing and Income from a Mine This is in reply to your correspondence of November 28, 2001 wherein you requested our views on the meaning of the term 'income from a mine' as used in subsection 1104(5) of the Income Tax Regulations (the "Regulations") and whether income from custom processing is included in income from a mine. ... " In Bethlehem Copper Corporation Ltd (74 DTC 6520), the Supreme Court stated that "... there is a mine within the meaning of s. 83(5) if there is a body of ore together with the workings, equipment and machinery capable of producing it. ...

10 July 2002 Internal T.I. 2001-0115657- FINANCING LEASE Unedited CRA Tags 18(1)(b) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... July 10, 2002 EDMONTON TSO HEADQUARTERS Verification and Enforcement Income Tax Rulings Directorate Attention: Donald Boyce N.L. ... The meaning of disposition of property has been interpreted broadly in Olympia & York 80 DTC 6185 (FCA) and Robert Bédard 85 DTC 643 (TCC) to include transactions or events that are not sales. ...

2 August 2002 Internal T.I. 2002-0148547- S. 17(1), application to taxation years Unedited CRA Tags S. 17 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... USco did not carry on an active business until 2002. 6. In XXXXXXXXXX 2000, Canco1's Canadian parent incorporated a numbered company in Canada ("Canco2"). ... As agreed with Brian Ellis (Ellis / Wong, July 30, 2002), we do not discuss in this reply the potential avoidance issues relating to these transactions undertaken in 2000, since these issues have been referred to Tax Avoidance. ...

20 September 2002 Internal T.I. 2002-0146627- Statute barred limits, Section 216S. 216; S. 152(8) Unedited CRA Tags S. 152(2); S. 152(3.1); S. 152(4) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... September 20, 2002 International Policy & Business HEADQUARTERS Management Division Income Tax Rulings Directorate Policy and Publications Unit I S. ... As you indicated in your June 11, 2002 memorandum, subsection 216(1) of the Act clearly states that the filing of a subsection 216(1) return does not affect the liability of the taxpayer for tax otherwise payable under Part I of the Act. ...

23 October 2002 Internal T.I. 2002-0135797- FOREIGN EXCHANGE LOSSES Unedited CRA Tags 20(1)(f) 39(2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... October 23, 2002 VANCOUVER TSO HEADQUARTERS Tom Markota Corporate Financing Section Audit Services G. ... In document # 9703377, we indicated that "for purposes of paragraph 20(1)(f) the principal amount under the terms of the CBL (Consumer Based Loan) is the total amount paid on maturity plus the total of all payments in satisfaction of principal paid over the life of the obligation. ...

31 October 2002 Internal T.I. 2002-0142497- FOREIGN EXCHANGE LOSSES Unedited CRA Tags 20(1)(f) 39(2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... October 31, 2002 MONTRÉAL TSO HEADQUARTERS Michel Hamelin M.Lambert Audit Services (613) 957-8953 2002-014249 Recharacterization of Foreign Exchange Losses to Amounts Deductible Under Paragraph 20(1)(f) of the Income Tax Act We are writing in reply to your memo of July 22, 2002, in which you requested our opinion regarding the recharacterization of foreign exchange losses from capital in nature to amounts deductible under paragraph 20(1)(f) of the Income Tax Act (the "Act"). ... In document # 9703377, we indicated that "for purposes of paragraph 20(1)(f) the principal amount under the terms of the CBL (Consumer Based Loan) is the total amount paid on maturity plus the total of all payments in satisfaction of principal paid over the life of the obligation. ...

27 November 2002 Internal T.I. 2002-0140507- FOREIGN EXCHANGE LOSS Unedited CRA Tags 20(1)(f) 39(2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... November 27, 2002 VANCOUVER TSO HEADQUARTERS Cliff Johnston Corporate Financing Section Manager G. ... In document # 9703377, we indicated that "for purposes of paragraph 20(1)(f) the principal amount under the terms of the CBL (Consumer Based Loan) is the total amount paid on maturity plus the total of all payments in satisfaction of principal paid over the life of the obligation. ...