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Les termes et modalités de cette entente sont spécifiés dans le projet de convention de règlement et transaction qui était joint à votre demande. 4.Les modalités du règlement prévoient, entre autres, des versements mensuels périodiques de XXXXXXXXXX $ indexés annuellement à 2% à compter du XXXXXXXXXX inclusivement et par la suite indexé à 3% à compter du XXXXXXXXXX inclusivement. ...

FAITS XXXXXXXXXX XXXXXXXXXX TRANSACTIONS PROJETÉES XXXXXXXXXX Vous nous avez transmis, le XXXXXXXXXX, une copie d'une convention de donation standard qui sera utilisée par XXXXXXXXXX pour les fins de la donation des XXXXXXXXXX. ...

Dans la situation que vous nous présentez, il est indiqué dans la convention collective que les employés en question sont des pompiers volontaires. ...

However, travel to conventions and business meetings in other cities or to other parts of the country would not be personal use. ...

Le XXXXXXXXXX, une convention de prise ferme a été conclue entre plusieurs maisons de courtage («Preneurs Fermes Canadiens»), OPCOI et GESTCO. En vertu de cette convention, les Preneurs Fermes Canadiens ont convenu d'acheter en date de clôture XXXXXXXXXX unités, sous réserve de certaines conditions énumérées dans la convention. ... La convention prévoyait qu'advenant l'exercice des XXXXXXXXXX BS2, XXXXXXXXXX actions ordinaires seraient émises par GESTCO et XXXXXXXXXX actions ordinaires seraient vendues par OPCOI. ...

DEFINITIONS In this advance ruling request, the following terms have the meanings specified: (a) XXXXXXXXXX; (b) "Act" means the Income Tax Act (Canada) R.S.C. 1985 (5th Supp.) c. 1 (as amended); (c) "Arm's Length" has the meaning assigned by section 251 of the Act; (d) "Canada-Luxembourg Tax Convention" means the Canada-Luxembourg Income Tax Convention, 1999; (e) "Canco1" means XXXXXXXXXX; (f) "Canco2" means XXXXXXXXXX; (g) "CRA" means the Canada Revenue Agency; (h) "Current Accounts Agreement" has the meaning set out in Part II, paragraph 10 herein; (i) XXXXXXXXXX; (j) "Finco" means a new entity to be established under the laws of the Duchy of Luxembourg as described in Part III, paragraph 21 herein; (k) "Forco1" means XXXXXXXXXX; (l) "Forco1 Receivable" has the meaning set out in Part II, paragraph 4(c) herein; (m) "Forco2" means XXXXXXXXXX; (n) "Forco3" means XXXXXXXXXX; (o) "Forco3 Receivable" has the meaning set out in Part II, paragraph 5(b) herein; (p) "Forco4" means XXXXXXXXXX; (q) XXXXXXXXXX; (r) "Lux Law" means the relevant corporate and commercial laws of the Duchy of Luxembourg; (s) "MRPS" means the mandatorily redeemable preferred shares to be issued by Finco; (t) XXXXXXXXXX; (u) "Related Persons" has the meaning assigned by section 251 of the Act; and (v) "Shareholder's Agreement" means the XXXXXXXXXX agreement among Forco3, Forco2, XXXXXXXXXX, Canco1, and Forco1 as more particularly described in Part II herein. ... Finco will be resident in Luxembourg for purposes of the Act and the Canada-Luxembourg Tax Convention and will have a XXXXXXXXXX taxation year end. 22. ...

.), as amended to the date hereof, and unless otherwise stated, every reference herein to a Part, section, subsection, paragraph or subparagraph is a reference to the relevant provisions of the Act; (b) "Authority" means the Irish Financial Services Regulatory Authority, fulfilling the duties of the Central Bank and Financial Services Authority of Ireland set out in the Regulations; (c) "Chargeable Events" means those events set out in Section 739B of the Taxes Consolidation Act, 1997 (Ireland), which include any payment of gross income to Unitholders or any encashment, redemption, cancellation or transfer of units; (d) "Common Contractual Fund" means a common contractual fund authorized by the Authority under the Regulations and meeting the conditions set out in Section 739C(1A) of the Taxes Consolidation Act, 1997 (Ireland), as amended; (e) "CRA" means the Canada Revenue Agency; (f) "Custodian" means the Irish branch of XXXXXXXXXX, a company incorporated in XXXXXXXXXX acting as custodian with respect to the Fund's property; (g) "Custodianship Agreement" means the agreement to be entered into between the Manager and the Custodian relating to the appointment and duties of the Custodian; (h) "Deed of Constitution" means the deed of constitution to be entered into between the Manager and the Custodian providing for the constitution of the Fund; (i) "Dutch Treaty" means the Canada-Netherlands Income Tax Convention; (j) "Fund" means the XXXXXXXXXX, a Common Contractual Fund to be constituted by the Manager; (k) "Gross Income Payments" means such payment or payments to Unitholders as may be determined by the Manager available out of net income and realized or unrealized net profit on the valuation of investments of the Sub-Fund; (l) "Irish Treaty" means the Canada-Ireland Income Tax Convention; (m) "Manager" means XXXXXXXXXX, a corporation incorporated and resident in XXXXXXXXXX. It has its registered office at XXXXXXXXXX, and it will act in its capacity as manager of the Fund; (n) XXXXXXXXXX; (o) "Prospectus" means the prospectus prepared in accordance with the Regulations and pursuant to which Unitholders acquire an investment in the Fund; (p) "Regulations" means Statutory Instrument No. 211 of 2003, European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations 2003, as amended; (q) "Sub-custodian" means XXXXXXXXXX incorporated in Canada and related to the Custodian; (r) "Sub-Fund" means a portfolio of assets within the Fund; (s) "Tax Treaties" means the Irish Treaty, UK Treaty and Dutch Treaty, as defined herein; (t) "UK Treaty" means the Canada-United Kingdom Income Tax Convention; (u) "Unit" means a unit of account, representing a proportionate undivided co-ownership interest in the property of a Sub-Fund as tenants in common with the other Unitholders of the Sub-Fund; and (v) "Unitholder" means a legal or natural person that is the beneficial owner of Units of a Sub-Fund. ...

"SOCIÉTÉ" Les XXXXXXXXXX propriétaires ou copropriétaires "Actionnaires-Occupants" Le Contrat d'occupation et convention conclu entre l'Actionnaire-Occupant et SOCIÉTÉ (dont une photocopie dudit "Contrat" Contrat pour un des anciens Actionnaires-Occupants était joint à votre demande) XXXXXXXXXX "Évaluateur" Immeuble situé au XXXXXXXXXX "Immeuble" "Capital versé" au sens de la définition prévue au paragraphe 89(1). ... En raison des nouvelles modalités de cette détention, les Actionnaires-Occupants procéderont entre eux à la réalisation d'une convention d'indivision ayant pour effet de se répartir, au moyen de droits d'occupation semblables aux Contrats, l'occupation de ces appartements. Par conséquent, la convention d'indivision stipulera toutes les dispositions devant régir l'indivision conventionnelle. 25. ...

.), as amended to the date hereof; (d) "active business" has the meaning assigned by subsection 95(1) of the Act; (e) "arm's length" has the meaning assigned by section 251 of the Act; (f) "B Co" means XXXXXXXXXX as described in Paragraph 9; (g) "B Co Shares" means shares of B Co as described in Paragraph 12; (h) "C Co Shares" means shares of XXXXXXXXXX as described in Paragraph 12; (i) "CBCA" means the Canada Business Corporations Act; (j) "CRA" means the Canada Revenue Agency; (k) "C Co" means XXXXXXXXXX as described in Paragraph 7; (l) "D Co" means XXXXXXXXXX as described in Paragraph 10; (m) "D Co Shares" means the shares of D Co as described in Paragraph 12; (n) "E Co" means XXXXXXXXXX as described in Paragraph 9; (o) "E Co Leasing" means a subsidiary of a XXXXXXXXXX holding company directly held by E Co as described in Paragraph 9; (p) "fair market value" means the amount at which property would exchange hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of the relevant facts; (q) "H Co " means XXXXXXXXXX as described in Paragraph 10; (r) "I Co" means XXXXXXXXXX as described in Paragraph 9; (s) "IF Co" means XXXXXXXXXX. as described in Paragraph 8; (t) "LP" means XXXXXXXXXX and Company LP as described in Paragraph 8; (u) "New LP" means a new limited partnership as described in Paragraph 20; (v) "Note" means a promissory note issued by A Co to W Co as described in Paragraph 15; (w) "paid-up capital" has the meaning assigned by subsection 89(1) of the Act; (x) "Paragraph" means a numbered paragraph in this advance income tax ruling; (y) "Preference Shares" means voting preference shares of A Co as described in Paragraph 6; (z) "principal amount" has the meaning assigned by subsection 248(1) of the Act; (aa) "Proposed Transactions" means the proposed transactions described in Paragraphs 22 to 29; (bb) "Regulations" means Income Tax Regulations, Consolidated Regulations of Canada, Chapter 945 as amended to the date hereof; (cc) "Reinvestment Agreement" means an agreement between T Co, A Co and W Co as described in Paragraph 18; (dd) "related persons" has the meaning assigned by subsection 251(2) of the Act; (ee) "Share Transfer Agreement" means a share transfer agreement entered into by A Co and W Co as described in Paragraph 12; (ff) "taxable Canadian corporation" has the meaning assigned by subsection 89(1) of the Act; (gg) "T Co" means XXXXXXXXXX as described in Paragraph 11; (hh) "third parties" means persons who act at arm's length with the X Group; (ii) "Transferred Shares" has the meaning described in Paragraph 12; (jj) "Treaty" means the Canada-United States Income Tax Convention; (kk) "W Co" means XXXXXXXXXX as described in Paragraph 2; (ll) "X Co" means XXXXXXXXXX as described in Paragraph 1; (mm) "X Group" means X Co and entities related to X Co; (nn) "Z Co" means XXXXXXXXXX, as described in Paragraph 6. ... E Co is a resident of XXXXXXXXXX for purposes of the Canada-XXXXXXXXXX Income Tax Convention. ... D Co is a resident of XXXXXXXXXX for the purposes of the Act and the Canada-XXXXXXXXXX Income Tax Convention. ...

Subfunds are not subdivided into sub-classes or series; j) XXXXXXXXXX; k) XXXXXXXXXX; l) “CRA” means the Canada Revenue Agency; m) “Custodian Bank” means XXXXXXXXXX, having its registered office at XXXXXXXXXX and acting as custodian with respect to the XXXXXXXXXX property as set out in the Fund Contract; n) “Designated Stock Exchanges” has the meaning assigned by section 262; o) XXXXXXXXXX; p) “Fund Contract” means the fund contract dated XXXXXXXXXX, entered into force on XXXXXXXXXX between the Investor, the Management Company and the Custodian Bank, providing for the establishment of the XXXXXXXXXX; q) “Investment” means a permitted investment set out in Section XXXXXXXXXX of the Fund Contract; r) “Investor” has the meaning assigned in the Fund Contract and is currently restricted to the Pension Fund; s) “Management Company” means XXXXXXXXXX, having its registered office at XXXXXXXXXX, acting in its capacity as the fund management company of the XXXXXXXXXX as set out in the Fund Contract; t) “Non-Resident” has the meaning assigned by subsection 248(1); u) “Open-ended XXXXXXXXXX” means a XXXXXXXXXX, established under the laws of XXXXXXXXXX, authorised by the Authority pursuant to XXXXXXXXXX; v) “Open-ended XXXXXXXXXX with Subfunds” means an Open-ended XXXXXXXXXX, established under the laws of XXXXXXXXXX, authorized by the Authority pursuant to XXXXXXXXXX; w) “Other Securities Funds” means Open-ended XXXXXXXXXX, established under the laws of XXXXXXXXXX, authorized by the Authority pursuant to XXXXXXXXXX that are neither securities funds nor real estate funds; x) “Pension Fund” means XXXXXXXXXX Pension Fund, a pension fund that provides occupational benefits for employees and members of the public authorities of XXXXXXXXXX formed under the laws of XXXXXXXXXX and is described in XXXXXXXXXX; y) “Related Persons” has the meaning assigned by subsection 251(2); z) “Subfund” means, XXXXXXXXXX, each a XXXXXXXXXX, in its own right, within an Umbrella Fund; aa) “Taxpayer” has the meaning assigned by subsection 248(1); bb) “Tax Treaty” means the Convention between Canada and XXXXXXXXXX For the Avoidance of Double Taxation with Respect to Taxes on Income and on Capital signed on XXXXXXXXXX as amended by the Protocol of XXXXXXXXXX; cc) “TCP” means taxable Canadian property as defined in subsection 248(1); dd) “Umbrella Fund” means, an Open-ended XXXXXXXXXX with Subfunds; ee) “Unit” means a claim against the Management Company conferring entitlement to the assets and income of a Subfund of a XXXXXXXXXX; and ff) “Unitholder” means any Investor holding a Unit of a Subfund as being the holder of a Unit such holder being legally entitled to a share in the undivided assets of the Subfund, which are not segmented. ... In particular, nothing in this ruling should be construed as implying that the CRA has considered, examined, agreed to or ruled on whether: (a) any Unitholder would be considered to be carrying on business in Canada because of the provision of services to the Unitholder by the Sub-Custodian in reference to the Unitholder’s investments in Canadian securities and consequently, whether the income in respect of the investments referred to herein would be taxable under Part I or Part XIII; (b) any Unitholder is a resident of a country with which Canada has entered into a Tax Treaty, or the manner in which any article of a Tax Treaty applies to any Unitholder; or (c) a Canadian payer and the Canadian Sub-custodian have complied with the withholding requirements under Part XIII (including guidance in respect of financial intermediaries provided in IC76-12R6 “Applicable rate of part XIII tax on amounts paid or credited to persons in countries with which Canada has a tax convention”, and on the CRA webpage “Pending updates to IC76-12, Applicable rate of part XIII tax on amounts paid or credited to persons in countries with which Canada has a tax convention related to forms NR301, NR302, and NR303” in respect of the amounts paid or credited to the Canadian Sub-custodian and the amounts paid or credited by the Canadian Sub-custodian to Unitholders. ...