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The Employer will pay all brokerage fees arising in connection with the acquisition of such Shares. ...

(g) In connection with the transfer of the Private Equity Assets to Investment Holdco and Investment Holdco 2, Investment Holdco and Investment Holdco 2 will succeed to any rights and obligations of the Fund under shareholders', limited partnership or similar agreements relating to the transferred Private Equity Assets, including the Cash Call Obligations that relate to the Private Equity Assets that it has received. ...

It requires a community of interest in the performance of the subject matter, a right to direct and govern the policy in connection therewith, and duty, which may be altered by agreement, to share both in profit and losses. ...

In this connection, at page 5420 Justice Heald states: "The respondent relies on the Privy Council case of Punjab Co-operative Bank Limited v. ...

We suggest that the tax treatment of "financial leases" be incorporated in the general discussion as described in Attachment "B". 6) Application of Subsections 13(5.1), 13(5.2) and 13(5.3) We recommend that paragraphs 8 to 11 be incorporated under a common sub-heading such as "Dispositions and Acquisitions of Property in Connection with certain Leasing Arrangements". ...

This same rationale should be applied when considering the taxable portion of benefits provided in connection with the other named conferences. ...

In this connection, at page 5420 Justice Heald states: “The respondent relies on the Privy Council case of Punjab Co- operative Bank Limited v. ...

A subsidiary issue in connection with 2) above, is whether any portion of the instalment payment is on account of interest. ...

To the best of your knowledge and that of Opco none of the issues in respect of which rulings are herein requested is: (a) in an earlier return of Opco or a related person, (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of Opco, (c) under objection by Opco or a related person, (d) before the courts or, it a judgment has been issued, the time limit for appeal to a higher court has not expired, and (e) the subject of a ruling previously issued by the Income Tax Rulings and Interpretations Directorate. 8. ...

To the best of your knowledge and the knowledge of the Employer, none of the issues involved in this ruling request is being considered by a tax services office or taxation centre in connection with an income tax return already filed, and none of the issues is under objection or appeal. ...