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2005 Ruling 2005-0147181R3- Reorganization under 132.2 The following document was issued prior to the September 19, 2005 announcement that the provision of advance income tax rulings on income trusts and other flow-through entities would be postponed while the Department of Finance consultations are underway and until the government announces what action it may take. SUBJECT: Reorganization under 132.2 XXXXXXXXXX XXXXXXXXXX, 2005 Dear Messrs: Re: Advance Income Tax Ruling XXXXXXXXXX (XXXXXXXXXX Tax Services Office, XXXXXXXXXX Taxation Centre) XXXXXXXXXX (XXXXXXXXXX Tax Services Office) This is in reply to your emails dated XXXXXXXXXX in which you requested amendments to the facts and proposed transactions set out in the Advance Income Tax Ruling letter (document # 2005-011989) issued to the above-referenced taxpayers on XXXXXXXXXX, 2005 (the Ruling). ...

February 25, 2005 Kathie Cameron HEADQUARTERS Tax Avoidance Section Kitchener/ Income Tax Rulings Waterloo Tax Services TSO Directorate 166 Frederick Street Yves Moreno Kitchener ON (613)952-1764 2005-011352 This is in response to your fax dated January 27, 2005, concerning transactions whereby a capital gain and an offsetting capital losses have been triggered. ... A file involving the issuance of high/low preferred shares to trigger a capital loss without an economic loss was submitted to the attention of the GAAR committee on February 15, 2005. ... Murphy for Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

February 25, 2005 Kathie Cameron HEADQUARTERS Tax Avoidance Section Kitchener/ Income Tax Rulings Waterloo Tax Services TSO Directorate 166 Frederick Street Yves Moreno Kitchener, ON (613)952-1764 2005-011353 This is in response to your fax dated January 27, 2005, concerning transactions whereby a capital loss has been claimed by the taxpayer as a result of a series of transactions designed to eliminate the tax payable on a capital gain realized by the taxpayer. ... A file involving the issuance of high/low preferred shares to trigger a capital loss without an economic loss was submitted to the attention of the GAAR committee on February 15, 2005. ... Murphy for Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

February 25, 2005 Kathie Cameron HEADQUARTERS Tax Avoidance Section Kitchener/ Income Tax Rulings Waterloo Tax Services TSO Directorate 166 Frederick Street Yves Moreno Kitchener ON (613) 952-1764 2005-011354 This is in response to your fax dated January 27, 2005, concerning transactions whereby a capital loss has been claimed by the taxpayer as a result of a series of transactions designed to eliminate the tax payable on a capital gain realized by the taxpayer. ... A file involving the issuance of high/low preferred shares to trigger a capital loss without an economic loss was submitted to the attention of the GAAR committee on February 15, 2005. ... Murphy for Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

5 August 2005 Internal T.I. 2005-0131461I7- definition of "restricted financial institution" Unedited CRA Tags 248(1) "restricted financial institution" (e) Principal Issues: meaning of "such persons" in paragraph (e) of definition of "restricted financial institution" in subsection 248(1) Position: persons with whom the corporation is dealing at arm's length Reasons: wording of ITA / basic grammar August 5, 2005 TORONTO NORTH TSO HEADQUARTERS Technical Applications and Denise Dalphy, LL.B. Valuations Division 613 941-1722 Attention: Angelo Bertolas Banking Industry Specialist 2005-013146 Definition of "restricted financial institution" This is in response to your e-mail of May 3, 2005 wherein you requested our interpretation of paragraph (e) of the definition of "restricted financial institution" in subsection 248(1) of the Income Tax Act (the "Act"). ...

6 July 2005 External T.I. 2005-0125271E5- Wilthholding of income tax Unedited CRA Tags 104(13) 104(13.1) Principal Issues: Does the trustee have to deduct or withhold an amount of income tax from the payment of the income payable to a Canadian resident by a trust? ... XXXXXXXXXX 2005-012527 July 6, 2005 Dear XXXXXXXXXX: Re: Income from the Estate of XXXXXXXXXX We are writing in response to your letter of January 23, 2005 wherein you requested information concerning the withholding or the deduction of income tax on the income you received from the estate of XXXXXXXXXX (hereinafter the "Trust"). ... Yours truly, Alain Godin, Manager for Director International and Trusts Division Income Tax Rulings Directorate Policy and Planning Branch c.c.: Bernice Stratton Problem Resolution & Operations Support Section ...

16 February 2005 Internal T.I. 2005-0114671I7- Successor Pool Allocation Unedited CRA Tags 66.7(3) 66.7(4) 66.7(5) Principal Issues: Whether, for the purpose of determining the deduction from income from a particular property acquired by a successor corporation, the successor pool is required to be apportioned to each particular property, based on whether the expenses in the pool related to the particular property. ... February 16, 2005 Ms. Christine Savage Reorganizations & Resources Industry Specialist Services Division 112 Kent Street, 13th Floor, Tower B Marc Edelson, LL.B. ... Zul Ladak, Oil and Gas Industry Specialist, of the Technical Applications and Valuation Division, Calgary Tax Services TSO, dated February 4, 2005, and subsequent communications. ...

11 March 2005 External T.I. 2005-0116071E5- Paragraph 67.1(2)(f) of the ITA Unedited CRA Tags 67.1(1) 67.1(2) Principal Issues: Whether the comments in paragraph 12 of IT-518R concerning the application of the former paragraph 67.1(2)(e) of the Act, apply in respect of the application of paragraph 67.1(2)(f)? ... Randy Hewlett XXXXXXXXXX 613-941-7239 2005-011607 March 11, 2005 Dear XXXXXXXXXX: Re: Paragraph 67.1(2)(f) of the Income Tax Act (the "Act") We are writing in response to your letter of February 9, 2005, wherein you inquired whether the comments in paragraph 12 of Interpretation Bulletin IT-518R, Food, Beverages and Entertainment Expenses, apply in respect of the application of paragraph 67.1(2)(f). ... For taxation years ending prior to that time, a similar exception was contained in the former paragraph 67.1(2)(e) of the Act, which applied in respect of amounts " incurred by the person for food, beverages or entertainment generally available to all employees of the person at a particular location. ...

24 March 2005 External T.I. 2004-0092221E5- rollover of family farm property on death Unedited CRA Tags 70(9) 248(5) Principal Issues: 1. ... XXXXXXXXXX 2004-009222 March 24, 2005 Dear Madame: Re: Transfer of Farm Property to Child on Death This is in reply to your letter of August 24, 2004. ... Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

6 May 2005 External T.I. 2004-0078561E5- Withholding on services outside Canada Unedited CRA Tags 153 Principal Issues: The employee works for a non-resident employer outside of Canada. ... Thomson May 6, 2005 Dear XXXXXXXXXX: Re: Withholdings From Wages This is in reply to your email of May 26, 2004 in which you ask for information regarding withholdings from your salary. ... Or, you may contact the International Tax Services Office, Enquiries & Adjustments Division, at 1-800-267-5177 (toll free in Canada and the U.S.), or (613) 952-3741. ...