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ACO is controlled by BCO, a corporation that is not resident in Canada for purposes of the Act and that is resident in XXXXXXXXXX for purposes of the Canada-XXXXXXXXXX Income Tax Convention. ...

Our understanding of the facts, proposed transactions and the purpose of the proposed transactions is as follows: Definitions (a) "Parent" means XXXXXXXXXX; (b) "Subco" means XXXXXXXXXX; (c) "Foreignco" means XXXXXXXXXX; (d) "DC" means XXXXXXXXXX; (e) "Articles" means the articles to be attached to the notarial deed creating DC which notarial deed will be filed with the appropriate "commercial register" in the Foreign Country; (f) "CRA" means the Canada Revenue Agency; (g) "CBCA" means the Canada Business Corporations Act; (h) "Foreign Country" means XXXXXXXXXX; (i) "Foreign Legislation" means the XXXXXXXXXX; (j) "adjusted cost base" ("ACB") has, by virtue of subsection 248(1) of the Act, the meaning assigned by section 54 of the Act; (k) "arm's length" has the meaning assigned by subsection 251(1) of the Act; (l) "capital property" has, by virtue of subsection 248(1) of the Act, the meaning assigned by section 54 of the Act; (m) "corporation" has the meaning assigned by subsection 248(1) of the Act; (n) "foreign affiliate" has, by virtue of subsection 248(1) of the Act, the meaning assigned by subsection 95(1) of the Act; (o) "controlled foreign affiliate" has, by virtue of subsection 248(1) of the Act, the meaning assigned by subsection 95(1) of the Act; (p) "proceeds of disposition" has the meaning assigned by section 54 of the Act; (q) "public corporation" has, by virtue of subsection 248(1) of the Act, the meaning assigned by subsection 89(1) of the Act; (r) "related persons" has the meaning assigned by subsection 251(2) of the Act; (s) "share" has the meaning assigned by subsection 248(1) of the Act; (t) "specified participating interest" has the meaning assigned by the proposed amendment to subsection 248(1) of the Act contained in Bill C-10 (passed by the House of Commons on October 29, 2007); (u) "subsidiary wholly-owned corporation" has the meaning assigned by subsection 248(1) of the Act; (v) "taxable Canadian corporation" has, by virtue of subsection 248(1) of the Act, the meaning assigned by subsection 89(1) of the Act; and (w) "Treaty" means the Canada-XXXXXXXXXX Income Tax Convention. ...

In addition, nothing in this letter should be construed as confirmation, express or implied, that the CRA has reviewed or agreed to: a. the country of residence at any time of BCo, CCo or DCo 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 fair market value or adjusted cost base of any property or the amount of stated capital or paid-up capital of any share referred to in this letter; or c. the income tax consequences in XXXXXXXXXX or XXXXXXXXXX. ...

Une convention interviendra à cet effet entre Société A et Société B. ...

.; (h) "CanSub2" is XXXXXXXXXX; (i) "NSULC" is an unlimited liability company existing under the XXXXXXXXXX (j) "taxable Canadian corporation" has the meaning assigned by subsection 89(1) of the Act; (k) "Treaty" means the Convention between Canada and the United States of America With Respect to Taxes on Income and on Capital, which was signed on September 26, 1980 and amended by subsequent protocols; (l) "Code" means the United States Internal Revenue Code; (m) "Foreign Stock Exchange" is the XXXXXXXXXX Stock Exchange; and (n) "Foreign Country" is the United States of America. ...

In this letter, unless otherwise expressly stated: a) "Austrian Tax Treaty" means the Convention Between Canada and the Republic of Austria for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital; b) "Financial Market Authority" means the Austrian Financial Market Authority; c) "CRA" means Canada Revenue Agency; d) "Custody Agreement" means the Depotbank Contract entered into on XXXXXXXXXX between the Investment Company and Aco's XXXXXXXXXX branch with respect to the appointment of and duties of Aco as custodian for the Funds and other Investment Funds; e) "Fund A" means the XXXXXXXXXX, an Austrian Publikumsfond established under the Investment Funds Act; f) "Fund B" means the XXXXXXXXXX, an Austrian Spezialfond established under the Investment Funds Act; g) "Fund Provisions" means the General Fund Provisions of XXXXXXXXXX, which govern the legal relationship between the Unitholders and Investment Company in respect of Fund B; h) "Funds" means Fund A and Fund B collectively; i) "Income Tax Regulations" means the Income Tax Regulations, C.R.C., c. 945, as amended to the date hereof; j) "Investment Company" means the XXXXXXXXXX; k) "Investment Fund" means a fund that is governed and regulated by the Investment Funds Act and the Financial Market Authority; l) "Investment Funds Act" means the Austrian Investment Fund Act of 1993 [Investmentfondsgesetz 1993]; m) "Tax Treaty" means a "tax treaty" as defined in subsection 248(1); n) "Unit" means a unit of account, representing one undivided share in the assets of an Investment Fund; and o) "Unitholder" means a person who holds Units of an Investment Fund. ...

Tax Convention. 11. Under the terms of the Agreement, DCo will be obliged to pay to the Taxpayer an amount equal to XXXXXXXXXX% of the Taxpayer's Pre-tax losses (determined before the inclusion of the XXXXXXXXXX% payment from DCo) on the distribution of the Products, excluding the X equipment. 12. ...

Tax Convention, (1980), ("Canada/U.S. Tax Treaty") or such other tax treaty as may be applicable); or (II) a XXXXXXXXXX elects to have assets held on his behalf transferred to the U.S. ...

Unless otherwise stated, statutory references in this letter are to the Act; b) "business" has the meaning assigned by subsection 248(1) of the Act; c) "Canadian corporation" has the meaning assigned by subsection 89(1) of the Act; d) "Canco Debt A" means the indebtedness owing by Canco to US Parent in the amount of $XXXXXXXXXX pursuant to an agreement entered into between US Parent and Canco on XXXXXXXXXX; e) "Canco Debt B" means the indebtedness owing by Canco to the Partnership in the amount of $XXXXXXXXXX pursuant to an agreement to be entered into between the Partnership and Canco as described in the proposed transactions; f) "carrying on business" has the meaning assigned by its extended meaning under subsection 253(1) of the Act; g) "corporation" has the meaning assigned by subsection 248(1); h) "taxable Canadian corporation" has the meaning assigned by subsection 89(1) of the Act; and, i) "the Treaty" means the Canada-United States Income Tax Convention, 1980, as amended. ...

Par convention datée du XXXXXXXXXX et intervenue entre Société D et Société A, cette dernière a transféré certains équipements et autres actifs de Entité C à Société D. ...