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September 16, 2011 XXXXXXXXXX Lita Krantz Assistant Director XXXXXXXXXX Tax Services Office International & Trusts Division Income Tax Rulings Directorate 2010 – 038357 Transfer of Property from a Canadian Branch to a US Head Office Further to your request and subsequent communications with the auditor relating to the above subject we are providing our comments on the two issues identified below. ... FACTS The following facts were provided: a) A Canadian Branch ("Branch") of a US corporation acquired certain machinery and equipment ("equipment") in the 2002 and subsequent taxation years. b) The cost of the equipment was recorded in the accounting records of the Branch operation in CDN$ and in US$ in the US corporation's accounting records. c) In 2007 the equipment, along with other capital and intangible assets ("assets"), were transferred to the US Head Office due to the winding down of the Branch. d) The Branch remained in existence in 2007 and subsequent taxation years (not known how long) for the purposes of leasing certain property. e) The transfer of the equipment was recorded in the accounting records as a disposition by the Branch for proceeds equal to NBV. f) Significant foreign exchange losses were reported for some of the asset transfers. g) A loan in US$ was given by the US Head Office to the Branch for the acquisition of Goodwill and Inventory. ...

B. (613) 957-8984 2002-016821 Part I.3- Life Insurance Reserves We are writing in response to your e-mail of October 15, 2002 requesting our comments with respect to the interpretation of clause 181.3(1)(c)(ii)(B) of the Income Tax Act (the "Act"), in particular the interaction between sub-clauses (I) and (III) and (IV). ... Lee Workman Manager Financial Institutions Section Financial Industries Division Income Tax Rulings Directorate Policy and Legislation Branch APPENDIX Assumptions: Book Reserve Tax Reserve Doubtful accounts 500 400 Life insurance 700 900* * Net of policy loans of $50 Situation #1: Taxpayers' calculation under 181.3(1)(c)(ii)(B) Situation #2: Suggested calculation under 181.3(1)(c)(ii)(B) Situation #1 Situation #2 Subclause 181.3(1)(c)(ii)(B) (I) Book reserves non-life 500 500 life 700 700 1200 1200 (II) Tax reserves to the extent included in (I) 400 400 (III) Tax reserves to the extent included in (I) 700 700 (IV) Policy loans to the extent deducted in computing total in (III)* 50 0 Total of (II), (III), and (IV) 1150 1100 Capital under (B) 50 100 * MTAR before deduction of policy loans 950 Amount included in book reserve 700 Policy loan 50 Amount determined under (III) 700 Clearly the amount determined under subparagraph 138(3)(a)(i) is to be determined net of policy loans and therefore is 900. ...

It is the one thing which distinguishes a well established business from a new business at its first start. [...] ... En l'espèce, le contribuable désire attribuer XXXXXXXXXX $ aux contrats d'exploitation, afin d'effectuer le choix en vertu du paragraphe 14(1.01) de la LIR. ... Ces modifications proposées s'appliqueront aux dispositions d'immobilisations admissibles effectuées après le 19 décembre 2002, donc à la situation en l'espèce. ...

The CFA realized income in 2002 and a loss in the following year, 2003. ... While the draft legislation on the Taxation of Non-Resident Trusts and Foreign Investment Entities released by the Department of Finance in July 2005 proposes to change the computation of the Trust's income under section 94 for taxation years that begin after 2002, these proposals are expected to have no effect on the amount to be attributed to the Canadian Resident under subsection 75(2) in the situation described in this memorandum. ... Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Ainsi, le montant figurant au passif s'élevait à XXXXXXXXXX $ en XXXXXXXXXX, XXXXXXXXXX $ en XXXXXXXXXX, XXXXXXXXXX $ en XXXXXXXXXX et XXXXXXXXXX $ en XXXXXXXXXX. ... La Reine (C.A.F.), 2002 DTC 7113, pour déterminer s'il y a contrôle de fait. ... La Reine, 2002 DTC 1770 (C.C.I.); L.D.G. 2000 Inc. c. La Reine, 2003 DTC 82 (C.C.I.); Plomberie J.C. ...

In this regard, the Redemption Premium represents the compensation for the interest rate spread between the Notes' interest rate (XXXXXXXXXX %) at the time of their issuance and the interest rate available on the financial markets at the time the default occurred in XXXXXXXXXX (when the reinvestment interest rates were XXXXXXXXXX %- XXXXXXXXXX %). ... Based upon this further review of the Redemption Payment, XXXXXXXXXX prepared an amended analysis of the Redemption Premium portion of the Mandatory Redemption Payment on the Notes as described in paragraph 7 above as follows: Redemption Premium Series A Notes: Foreign Exchange on Principal $XXXXXXXXXX Foreign Exchange on Accrued Interest XXXXXXXXXX Make-Whole Amount XXXXXXXXXX $XXXXXXXXXX Series B Notes: Make-Whole Amount XXXXXXXXXX Other Waiver Costs XXXXXXXXXX Bond Forward Settlement XXXXXXXXXX Bank Fee XXXXXXXXXX Bank Fee XXXXXXXXXX Balance per G/L $XXXXXXXXXX Using the results of her analysis, XXXXXXXXXX determined that the components of the Class A Redemption Payment (paragraph 3(g)(a)) that comprise the Class A Notes Redemption Premium (paragraph 7 above) is as follows: Foreign Currency Exchange Total (i) Principal Repayment $ XXXXXXXXXX $ XXXXXXXXXX $ XXXXXXXXXX (ii) Accrued Interest $ XXXXXXXXXX $ XXXXXXXXXX $ XXXXXXXXXX (iii) Make-Whole Amount $ XXXXXXXXXX TOTAL $XXXXXXXXXX $ XXXXXXXXXX $ XXXXXXXXXX * * This amount reconciles to XXXXXXXXXX "Summary of Cashflows" for Series A. ... Steve Tevlin for Director Financial Industries Division Income Tax Rulings Directorate Policy and Legislation Branch ENDNOTES 1 See your Exhibit B, letter from XXXXXXXXXX. to CCRA dated November 19, 2002. ...

David Larsen Eliza Erskine Appeals Division International Section I Sudbury Tax Services Office 952-1361 1050 Notre Dame Avenue Sudbury ON P3A 5C1 2002-016886 Active Business Carried on in Canada and the Small Business Deduction ("SBD") We are writing in reply to your memo to us of October 11, 2002, regarding the above-noted subject matter. ... The taxpayer's SBD should have been based on an amount determined as follows: $XXXXXXXXXX (taxable income)- 10/3 of $XXXXXXXXXX (the allowed FTC) = $XXXXXXXXXX. ... As you requested, we have attached two recent documents (docs. # 2001-0105567 and # 2001-0114175), in which we discuss a situation somewhat similar to the one discussed in this memo. ...

Prior to December 31, 2002, a Cyprus LLC was subject to tax under Cyprus tax law based on the source of the income earned by the company. ... Olli Laurikainen, CA for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

When #CO redeemed the shares, the individual would have had a deemed dividend of: $XXXXXXXXXX (redemption amount)- $XXXXXXXXXX (PUC) = $XXXXXXXXXX. ... XXXXXXXXXX Additionally, a presentation on this type of scheme was made at the 2002 Canadian Tax Conference. ...

January 24, 2003 London Tax Services Office HEADQUARTERS Morris Zambon Bob Naufal, CMA Verification & Enforcement Division (613) 957-2744 2002-017628 1) Cost of Labour for M&P profits calculation 2) Revenue and salaries and wages paid by a partnership for purpose of Reg. 402(6) We are writing in response to your memorandum dated November 26, 2002, wherein you requested our interpretation of the phrase "fiscal period ending in or coinciding with" a taxation year in the circumstances described below. ...