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Diguer June 24, 1998 Dear Sir/Madam Re: Interest deductibility This is in reply to your letter dated March 20, 1998, which we received in our office on May 13, 1998, in which you requested our views with respect to a situation where a corporation declares a dividend and issues as consideration therefor an interest bearing note. ...

Our Comments To qualify as a medical expense under paragraph 118.2(2)(q) of the Act, an amount must be paid as a premium, contribution or other consideration to a private health services plan in respect of one or more of the individual, the individual’s spouse and any member of the individual’s household with whom the individual is connected by blood relationship, marriage or adoption. ...

We have given your request careful consideration. However, we note that we have consistently expressed our view in the past that in a situation similar to the one described above a U.S. corporation the shares of which is owned by a partnership is a foreign affiliate of the partnership and not a foreign affiliate of the partners of the partnership. 1 In the hypothetical situation described above, as LLC would generally be treated as a corporation for Canadian tax purposes, LLC would be a foreign affiliate of Pship and not a foreign affiliate of Canco or any other corporate partners of Pship. ...

Public company A (“Aco”) acquires all the stock of public company B (“Bco”) on a share-for-share exchange where the only consideration issued by Aco is ordinary common shares of its capital stock. ...

Please note that the comments set out in this letter are of a purely general nature and do not take into account considerations that might arise in the context of a specific transaction. ...

In order that an association or organization may obtain "approved" status, it is necessary that certain information and documents in respect of the association be submitted to this Department for consideration and approval. ...

The amount of reduction available would be based on the facts and circumstances surrounding each case (with consideration being given to the frequency and degree of loss of privacy and quiet enjoyment). ...

In consideration for the transfer, the transferor will receive shares of the holding company. ...

In order that an association or organization may obtain "approved" status, it is necessary that certain information and documents in respect of the association be submitted to this Department for consideration and approval. ...

As consideration for assuming the debt of XXXXXXXXXX referred to in paragraph 27 above, XXXXXXXXXX will reimburse XXXXXXXXXX Amalco for the financing expenses incurred by XXXXXXXXXX in connection with this debt by issuing and delivering to XXXXXXXXXX Amalco a non-interest-bearing demand promissory note (the "XXXXXXXXXX Reimbursement Note" and the "XXXXXXXXXX Reimbursement Note", respectively), the principal amount of which will be equal to one-half of such financing expenses. ...