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We understand that, to the best of your knowledge and that of the taxpayer, none of the issues involved in this ruling is: (i) in an earlier return of the taxpayer or a related person, (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or a related person, (iii) under objection by the taxpayer or a related person, (iv) before the courts, or (v) the subject of a ruling previously issued by the Directorate to the taxpayer or a related person. ... Consequently, the XXXXXXXXXX Court XXXXXXXXXX made an order on XXXXXXXXXX, in connection with the Proceedings, authorizing and directing Canco 2 to take such steps and execute such documents as may be necessary or desirable to commence a winding-up of the Non-Applicants. 7. In connection with the winding-up of the Non-Applicants, the XXXXXXXXXX Court XXXXXXXXXX established the Claims Process to identify Claims that could be made against them. ...

2007 Ruling 2006-0211941R3- Canadian exploration expense Unedited CRA Tags 66.1(6) Principal Issues: Whether certain expenses incurred in connection with a Bulk Sample Program related to a potential XXXXXXXXXX operation qualify as Canadian exploration expense (CEE). ... You have advised that to the best of your knowledge and that of the responsible officers of the Corporation, none of the issues raised in this ruling is (i) in an earlier return of the taxpayer or a related person, (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or a related person, (iii) under objection by the taxpayer or a related person, (iv) before the courts, or (v) the subject of a ruling previously issued to the taxpayers by the Income Tax Rulings Directorate. ... In connection with the Bulk Sampling Program, temporary facilities will be constructed at XXXXXXXXXX, which include XXXXXXXXXX. ...

We understand that to the best of your knowledge and that of the taxpayers involved none of the issues involved in this ruling is being considered by a Tax Services Office or a Taxation Centre in connection with any tax return already filed, and none of the issues involved in the requested rulings is the subject of any notice of objection or is under appeal. ... The Foundation’s Memorandum of Association states that the Foundation’s objects are, inter alia: (a) to carry on, without pecuniary gain to its shareholders, objects of a social welfare, civic improvement, pleasure or recreation (XXXXXXXXXX) nature and to establish, develop, maintain, operate, improve, enhance, repair, renovate and support (including by subsidizing costs that may otherwise be incurred) community-owned or community-operated XXXXXXXXXX facilities and programs or services used or useful in connection therewith; and (b) to raise funds, by means of a XXXXXXXXXX (the "Lottery"), subject to any law enacted by the legislature of the Province of XXXXXXXXXX, and to hold the same and apply the income or part thereof arising therefrom as may be decided by the directors of the Foundation to: (i) perform and provide services respecting the conduct, administration and management of the Lottery; (ii) pay Prizes in connection with the administration of the Lottery; and (iii) to the extent that the Foundation’s income exceeds its administrative costs and the amount required to pay Prizes, to apply the excess to support XXXXXXXXXX by payment of or making contributions toward the establishment, development, maintenance, improvement, enhancement, repair, renovation and other operating and capital costs, of whatsoever nature and kind, of or associated with community-owned XXXXXXXXXX facilities in XXXXXXXXXX, which are used by XXXXXXXXXX. 3. ... We confirm that the provisions of paragraph 40(2)(f) of the Act will apply to deem any Holder’s gain or loss from the disposition of the chance to win a Prize or a right to receive an amount as a Prize in connection with the Lottery to be nil. ...

In carrying out its duties as trustee, Canco will act solely through its officers and employees and a trust administrator, all of whom will be non-resident of Canada and will carry their duties in connection with the administration of the Offshore Trusts outside Canada. In this regard, Canco will enter into a Trust Administration Agreement (the "Administration Agreement") with Parentco under which Parentco will act as a trust administrator by providing administrative services in connection with accounting and reporting functions, the custody of securities and other assets, and the collection and depositing of funds. ... In particular, we have not commented on any tax consequences relating to the custody fees, if any, in connection with the custody agreements referred to in paragraph 11 above. ...

The employees of Canco are not employed primarily in connection with any activities or businesses described in subclauses 206(1.1))(d)(iii)(B)(I) through (III) of the Act. 10. ... The Trust owns shares of other taxable Canadian corporations which carry on similar businesses as Canco and each of which have at least five full-time employees in Canada, who are not employed primarily in connection with any activities or businesses described in subclauses 206(1. 1)(d)(iii)(B)(I) through (III) of the Act. 12. ... An existing operating corporation owned by the Trust, similar to Canco, with at least five (5) full-time employees who are not employed primarily in connection with any activities or businesses described in subclauses 206(1.l)(d)(iii)(B)(I) through (III) of the Act, would be transferred pursuant to subsection 85(1) of the Act to a new corporation which is similar to Holdco, in the same manner as described in paragraph 14. ...

We understand that to the best of your knowledge and that of the taxpayers involved none of the issues involved in this ruling request are being considered by a Tax Services Office or a Taxation Centre in connection with any tax return already filed, and none of the issues involved in the requested rulings is the subject of any notice of objection or is under appeal. ... In connection with the reorganization of the management of the companies and the establishment of the Fund and its acquisition of ACO, BCO and ACO entered into two agreements, a Management Agreement and a Services Outsourcing Agreement (collectively the "Material Agreements"). 6. ... BCO has also provided ACO with other strategic services, such as all required project management and oversight services in connection with a major expansion of ACO's principal operating facility XXXXXXXXXX. ...

Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère. xxxxxxxxxx xxxxxxxxxx 991046 xxxxxxxxxx Attention: xxxxxxxxxx XXXXXXXXXX, 1999 Dear Sirs: Re: Advance Income Tax Ruling xxxxxxxxxx This is in reply to your letter dated XXXXXXXXXX wherein you requested an advance income tax ruling on behalf of XXXXXXXXXX (the “Partnership") and the partners thereof, in connection with the proposed transactions described below. ... The Partnership and the XXXXXXXXXX Will file elections under subsection 97(2) of the Act and the equivalent election under the XXXXXXXXXX Tax Act, if necessary, in connection with the transfer of the XXXXXXXXXX Assets. 8. ... The net proceeds from the Offering will be used by the Partnership to repay the balance of the promissory notes owing to the XXXXXXXXXX in connection with the acquisition of the XXXXXXXXXX Assets. 12. ...

To the best of your knowledge, and that of the above-noted taxpayer, none of the issues involved in this advance income tax ruling are: (i) involved in an earlier tax return of the above-noted taxpayer or of a related person; (ii) being considered by a Tax Services Office or a Taxation Centre in connection with a previously-filed tax return of the above-noted taxpayer or of a related person; (iii) under objection by the above-noted taxpayer or by a related person; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (v) the subject of a ruling previously considered by the Income Tax Rulings Directorate in connection with the above-noted taxpayer or a related person. ... The Manager will: (a) administer the day-to-day operations of the LPs, including maintaining or arranging for the maintenance of proper and complete books and records in connection with the management and administration of the affairs of the LPs; (b) arrange for office space and equipment and the necessary executive, clerical and secretarial personnel of the Manager or other service providers involved in the administration of the day-to-day operations of the LPs; (c) retain and instruct legal, investment banking, tax, valuation, appraisal, engineering, marketing and other professional advisors and consultants on behalf of the LPs in connection with the identification, acquisition, holding or disposition of the Investments or the administration of the day-to-day operations of the LPs, and conduct and coordinate relations on behalf of the LPs with such advisors and consultants; (d) make or incur and pay certain expenses on behalf of the LPs as the Manager reasonably considers necessary; (e) prepare reports for the approval and use of the GPs, as and when required in respect of various topics, including allocations and distributions to the partners, operating expenses of the LPs, the financial position of the LPs and the status and value of investments made by the LPs; (f) arrange for the administration on behalf of the LPs of the payment of distributions from the LPs to the partners and supervise the processing and registration of subscriptions and transfers of interests in the LPs; (g) at the request of the GPs, arrange for assistance with and co-ordinate the preparation of accounting records and financial statements of the LPs by professionals and other service providers; (h) act as agent of the LPs in obtaining for the LPs such services as may be required in connection with the identification, acquisition and disposition of the Investments, paying the debts and fulfilling the obligations of the LPs and handling, prosecuting and settling any claims of the LPs; (i) consider, for the benefit of the LPs, all Investments that come to the attention of the Manager that meet the investment guidelines set out in the LP Agreements; (j) select the market, dealer or broker and negotiate, where applicable, commissions in connection with the purchase and sale of the Investments; (k) enter into agreements as agent and on behalf of the LPs and carry out all agreements entered into by the LPs; (l) arrange insurance on behalf of the LPs; (m) manage and employ the capital of the LPs in the exercise of the duties of the Manager, including the payment of operating expenses and the investment of capital on the instructions of the GPs; (n) conduct due diligence in relation to the proposed Investments and report the findings of such due diligence to the GPs and the LPs; (o) exercise all rights, powers, options, privileges and other powers incidental to ownership of the Investments held by the LPs as may be exercised by any person owning such property or securities in their own right provided that timely notice has been given to the Manager by the appropriate persons of the LPs' assets; (p) provided that the GPs have properly provided or have caused to be provided to the Manager the proxy materials and unless otherwise notified by the GPs, and further provided that timely notice has been given to the Manager by the appropriate persons of the LPs' assets, determine whether and in what manner to vote, and execute or cause to be executed proxies respecting the voting of, securities held by the LPs at all meeting of holders of such securities; (q) enter into agreements on behalf of the LPs with other LPs in respect of Investments held by each of them; (r) borrow funds in the name of the LPs; (s) manage, administer, conserve, develop, operate, transfer, convey and dispose of any and all assets of the LPs on the instructions of the GPs; and (t) execute any and all other deeds, documents and instruments and do all acts as may be necessary or desirable to carry out the intent and purpose of the Management Agreements in respect of managing the day-to-day operations and affairs of the LPs and in connection with the identification, acquisition, holding or disposition of the Investments. 18. ... The Manager's principal activity is acting as an investment manager in connection with the investing of funds by arm's length investors, and it is seeking to establish the LPs in the course of that business. ...

We also acknowledge the information provided in subsequent correspondence in connection with your request. ... The Canadian Agreement provides that the Canadian Sub-Custodian is responsible for withholding any amount of tax under the Act, including the Part XIII tax payable on any amount that a person resident in Canada pays or credits to Unitholders in connection with their holding of Fund Units. 9. The Canadian Agreement also provides that the Canadian Sub-Custodian shall keep Books and Records at the Canadian Place of Business to support: a) the assessment of any Unitholders for their liability for Tax, interest and penalties that may arise in connection with the Fund Units that they hold; and b) the determination of any amount that may be subject to the Withholding Tax Obligation, and that should be remitted to the Receiver General in connection with the Fund Units held by the Unitholders. ...

To the best of your knowledge and that of the taxpayers involved, none of the issues involved with this request: (i) is involved in an earlier return of the taxpayer or a related person; (ii) is being considered by a tax services office or a taxation centre in connection with a tax return already filed by the taxpayer or a related person; (iii) is under objection; or (iv) is before the courts or, if a judgement has been issued, the time limit for appeal has not expired. ... All costs and expenses paid in connection with the implementation and running of the Loan Arrangement, any security agreement and/or any other agreements pertaining thereto, shall be borne exclusively by Aco. ... Provided that all expenses described in subparagraph 14(c) above are paid as reimbursements for specific expenses incurred for the performance of services that are for the benefit of Aco in connection with the financing granted to Aco under the Credit Facility, such fees that are paid by Aco to Parentco, to the extent reasonable in the circumstances, will be exempt from tax under Part XIII by virtue of subparagraph 212(4)(b). ...