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Income Tax Convention (1980) (the "Canada- U.S. Treaty") in Canada nor does it carry on business in Canada. ...

B concluront une convention d'indemnisation afin de s'engager à respecter les dispositions du paragraphe 55(3.1) et indemniser les autres parties qui pourraient subir un dommage en cas de non-respect de cet engagement. ...

Nothing in this ruling should be construed as implying that CCRA has agreed to or reviewed: (a) the determination of the FMV or the cost amount of any particular asset or the PUC or V-day value of any shares referred to herein; (b) any tax consequences relating to the facts and proposed transactions described herein other than those specifically described in the rulings given above; and (c) the country of residence of Individual A or Individual F for the purposes of the Act or a particular income tax convention which has entered into force between Canada and another country. ...

Aucune convention ou résolution concernant la liquidation de OPCO ou la distribution de ses biens ne prévoiera qu'il y aura annulation par OPCO de ses actions lors de la liquidation. 31. ...

COMMENTS Nothing in this ruling should be construed as implying that the Canada Customs and Revenue Agency has agreed to or reviewed: (a) the country of residence of HoldCo, HoldCo2, XXXXXXXXXXCo or ParentCo for purposes of the Act or a particular income tax convention which has entered into force between Canada and another country; (b) the determination of the FMV or adjusted cost base of any particular asset or share or the PUC of any shares referred to herein; or (c) any tax consequences relating to the facts and proposed transactions described herein other than those specifically described in the rulings given above. ...

With regard to the purchase by XXXXXXXXXX/DC of XXXXXXXXXX/DC Common Shares held by a Dissenting Shareholder as described in Paragraph 24: (1) subject to the application of subsection 55(2), the Dissenting Shareholder will be deemed by paragraph 84(3)(b) to have received a dividend equal to the amount by which any payment from XXXXXXXXXX/DC to the Dissenting Shareholder in respect of the purchase of such person's shares exceeds the PUC of such shares immediately prior to their purchase; (2) subsections 212(2) and 215(1) will apply (subject to the provisions of any applicable income tax convention) to require XXXXXXXXXX/DC to withhold and remit XXXXXXXXXX% of the amount of any such dividend deemed to have been paid to a Dissenting Shareholder who is a non-resident person; and (3) paragraph (j) of the definition of "proceeds of disposition" in section 54 will apply to exclude the amount of such deemed dividend from the proceeds of disposition of the XXXXXXXXXX/DC Common Shares recognized by the Dissenting Shareholder as a result of the purchase of such shares by XXXXXXXXXX/DC. ...

In addition, nothing in this letter should be construed as confirmation, express or implied, that the CCRA has reviewed or agreed to: (a) the country of residence of Aco, Bco, AcoSub or BcoSub for the purposes of the Act or a particular income tax convention which may be in force between Canada and another country; (b) the determination of the FMV or ACB of any property or the amount of stated capital or PUC of any share referred to in this letter; (c) the income tax consequences of the events or transactions described in 21 above to Canco or NewCanco; (d) the income tax consequences in XXXXXXXXXX or XXXXXXXXXX or any consequences under the BCA1 or BCA3, as the case may be, of the transactions described in 13 and 15 above; (e) the income tax consequences of any of the events or transactions described in this letter to any amount that is or may be required to be computed in respect of any foreign affiliate of Canco or NewCanco under Part LIX of the Income Tax Regulations; or (f) the income tax consequences of any transaction or event that has already occurred, or may occur prior to, contemporaneously with, or subsequent to any of the proposed transactions described in this letter. ...

Income Tax Convention, where the individual is liable for tax in the U.S. by reason of his residence or domicile, the U.S. will have exclusive right to tax remuneration received during that period where the services are performed in the U.S.. ...

Tout RTD et tout autre remboursement auquel Cédante aurait droit en raison des opérations prévues aux présentes ou d’autres opérations, sera attribué en proportion de la valeur des actions du capital-actions de Cédante détenues par chacune de Cessionnaire 1 et Cessionnaire 2, conformément à la convention de liquidation. 62. ...

With regard to the purchase by DC of existing DC Common Shares and/or DC Preferred Shares from a dissenting holder as described in Paragraph 41 and subject to the application of subsection 55(2): (a) DC will be deemed by paragraph 84(3)(a) to have paid, and each dissenting holder will be deemed by paragraph 84(3)(b) to have received, a dividend, equal to the amount, if any, by which any payment from DC to a dissenting holder (exclusive of any interest awarded by a court) in respect of the purchase for cancellation of such dissenting holder's DC Common Shares or DC Preferred Shares, as the case may be, exceeds the amount of PUC attributable to such shares immediately before the purchase for cancellation; (b) the amount of any such dividend will be included in computing such dissenting holder's income under subsection 82(1) and paragraph 12(1)(j); and (c) subsections 212(2) and 215(1) will apply (subject to the provisions of any applicable income tax convention) to require DC to withhold and remit XXXXXXXXXX% of the amount of each such dividend that is paid to a dissenting holder who is a non-resident of Canada. ... With respect to the transfer of: (a) the assets by Forco2 to Forsub1, as described in Paragraph 32 above; and (b) the assets, other than the shares in Forsub2 and Investco, by Forco2 to Forsub4, as described in Paragraph 32 above; paragraph 95(2)(f.4) will apply in respect of such dispositions, such that: (c) where no election is made under clause 95(2)(f.4)(i)(B), Forco2 will be deemed to have disposed of each asset that is a specified property (within the meaning referred to in paragraph 95(2)(f.3)) for an amount equal to the ACB of such asset to Forco2 at the original disposition time; (d) the transferee will be deemed to have acquired each asset that is a specified property for an amount equal to the fair market value of the asset at the original disposition time; (e) Forco2's cost of a particular property received from the transferee in exchange for a specified property will be deemed to be the fair market value of the particular property at the original disposition time; (f) Forco2 will be deemed to have an unadjusted suspended income or gain at the original disposition time in respect of the disposition of each specified property equal to the amount determined under subparagraph 95(2)(f.4)(iv); and (g) Forco2 will be deemed to have income or capital gain from the disposition of a specified property equal to the amount prescribed to be the adjusted suspended income or gain (within the meaning set out in subsection 5913(1) of the Regulations) in respect of the specified property at the earlier of the times set out in subparagraphs 95(2)(f.5)(i) and (ii), which for greater certainty will occur upon the purchases for cancellation, as described in Paragraphs 48 and 49 above, and at such time, provided that Forco2 is resident in the United States for the purposes of both the Act and the Canada-United States Income Tax Convention, such income or gain will be included in the exempt earnings of Forco2 in respect of DC and will not give rise to any income, gain or capital gain of Forco2 that would be required to be included in computing Forco2's FAPI. ...