2015-0573321R3 Qualifying Environmental Trust

Principal Issues: 1. Whether the proposed Trust meets the definition of a “qualifying environmental trust” in subsection 211.6(1) of the Act. 2. Whether contributions made by the taxpayer to the Trust will be deductible in computing the taxpayer's income pursuant to paragraph 20(1)(ss) of the Act. 3. Whether Government of Canada bonds and Treasury Bills will be a “prohibited investment” of the Trust as that term is defined in subsection 211.6(1).

Position: 1. Yes 2. Yes provided that the Trust is a QET at the time of the contribution. 3. No.

Reasons: Legislative text.

Author: XXXXXXXXXX
Section: ss. 211.6, 20(1)(ss)

XXXXXXXXXX                                           
2015-057332

XXXXXXXXXX, 2015

Dear XXXXXXXXXX,

Re.:  Advance Income Tax Ruling
         XXXXXXXXXX

This is in reply to a letter dated XXXXXXXXXX requesting an advance income tax ruling on behalf of XXXXXXXXXX. We have also received XXXXXXXXXX’s letter dated XXXXXXXXXX requesting that XXXXXXXXXX, in its capacity as a trustee as described above, be part of this advance income tax ruling.

To the best of your knowledge and that of the taxpayers involved, none of the issues contained in this ruling is:

(a)   in a previously filed income tax return of any of the taxpayers or a related person; being considered by a Tax Services Office or a tax centre in connection with a previously filed income tax return of any of the taxpayers or a related person;

(b)   under objection by any of the taxpayers or a related person;

(c)   before the courts; or

(d)   the subject of a ruling previously issued by the Income Tax Rulings Directorate involving any of the taxpayers or a related person.

Unless otherwise stated, all statutory references are to the Income Tax Act, R.S.C.  1985, c. 1 (5th Supp.), as amended to the date of this letter (the “Act”), and all terms and conditions used herein that are defined in the Act have the meaning given in such definition.

DEFINITIONS

In this letter, the following terms or expressions have the meaning specified:

“ACo” means XXXXXXXXXX incorporated under the laws of the Province of XXXXXXXXXX;

“ACo Pipeline” means XXXXXXXXXX;

“ACo Reclamation Trust” means the trust settled as described in paragraph 14 and governed by the terms contained in the ACo Trust Agreement;

“ACo Trust Agreement” means the XXXXXXXXXX entered into by the Trustee and ACo on XXXXXXXXXX and approved by the NEB on XXXXXXXXXX, the relevant terms of which are summarized in paragraph 14 below;

“affiliated persons” has the meaning assigned to that phrase in section 251.1; 

“Annual Contribution Amount” in respect of the ACo Reclamation Trust or the BCo Reclamation Trust means the amount equivalent to the identifiable charges collected annually to pay for the future cost of Reclamation Obligations with respect to a particular Pipeline and any amount ordered by the NEB;

“BCo” means XXXXXXXXXX incorporated under the laws of the Province of XXXXXXXXXX, acting in its capacity as general partner for BCo L.P.;

“BCo L.P.” means XXXXXXXXXX, a limited partnership formed under the laws of the Province of XXXXXXXXXX;

“BCo Pipeline” means XXXXXXXXXX;  

“BCo Reclamation Trust” means the trust settled as described in paragraph 16 and governed by the terms contained in the BCo Trust Agreement;

“BCo Trust Agreement” means the XXXXXXXXXX entered into by the Trustee and BCo, as general partner for and on behalf of BCo L.P., on XXXXXXXXXX and approved by the NEB on XXXXXXXXXX, the relevant terms of which are summarized in paragraph 16 below;

“Beneficiaries of the ACo Reclamation Trust” means any person, including a partnership, acting in its own capacity or acting on behalf of a partnership, that has Reclamation Obligations in respect of the ACo Pipeline from time to time, including ACo, and the Orphan Pipeline Fund;

“Beneficiaries of the BCo Reclamation Trust” means any person, including a partnership, acting in its own capacity or on behalf of a partnership, that has Reclamation Obligations in respect of the BCo Pipeline from time to time, including ACo, BCo, BCo L.P., and the Orphan Pipeline Fund;

“CCo” means XXXXXXXXXX incorporated under the laws of the Province of XXXXXXXXXX;

“Canadian partnership” has the meaning assigned by subsection 102(1);

“Company” means the person holding the regulatory authorization(s) for the time being to operate the applicable Pipeline, whether on its own behalf or on behalf of one or more persons and for the purposes of this letter includes ACo and BCo;

“NEB” means the National Energy Board, a board established under the National Energy Board Act, R.S.C. 1985, c. N-7, as amended, or any successor administrative body having authority to regulate ACo and BCo in respect of the operation and abandonment of the Pipelines;

“NEB MH-001-2013 Decision” means the NEB Reasons for Decision MH-001-2013 Set-aside and Collection Mechanisms, dated May 2014;

“Orphan Pipeline Fund” means a not-for-profit corporation that will be established pursuant to a statute of the Parliament of Canada and will maintain funds for the purpose of funding the reclamation of abandoned pipelines in Canada, consistent with the NEB Reasons for MH-001-2013 Decision;

“Pipeline” or “Pipelines” means one or both of the ACo Pipeline and BCo Pipeline, as the context requires, as described herein;

“qualifying environmental trust” or “QET” has the meaning assigned to that term in subsection 211.6(1);

“Qualified Investments” means all or any of those investments that from time to time are qualified investments for a qualifying environmental trust (being, as of the date hereof, only those types of property described in each of paragraphs (a), (b), (c), (c.1), (d) and (f) of the definition of “qualified investment” in section 204) and that are not a “prohibited investment” as this term is defined in subsection 211.6(1);

“Reclamation Obligations” means with respect to any location or locations in Canada used for the operation of a particular Pipeline, the duty to:

      (a) carry out the physical abandonment, decommissioning or deactivation of the Pipeline, within the meaning ascribed to these terms by the National Energy Board Onshore Pipeline Regulations (SOR/99-294), as amended from time to time; including without limitation the duty to bear all costs incurred to satisfy any conditions imposed by the NEB in any order or direction approving such decommissioning or deactivation of the Pipeline or granting leave to abandon the Pipeline;

      (b) develop abandonment plans with respect to the Pipeline, and prepare applications for leave to abandon or for approval of the deactivation or decommissioning of the Pipeline; and

      (c) carry out post-abandonment monitoring and remediation of the Pipeline Site, where post-abandonment refers to the period of time after the conditions of an order or direction issued by the NEB granting leave to abandon have been satisfied;

“related persons” or “persons related to each other” has the meaning assigned to that phrase in subsection 251(2);

“Site” with respect to a Pipeline means the location or locations in Canada used for the operation of that Pipeline;

“Statement of Investment Policies and Procedures” means a written statement of investment policies and procedures approved by the Company prior to implementation, in respect of a Trust Fund’s portfolio of investments, and shall set out broad policies and procedures for the Qualified Investments of the Trust Fund;

“TSO” means the Tax Service Office;

“taxable Canadian corporation” has the meaning assigned by subsection 89(1);

“Trust Fund” means the property held pursuant to the applicable ACo Trust Agreement or BCo Trust Agreement as shall exist from time to time together with any earnings, profits, increments and accruals arising therefrom, including all amounts delivered to and accepted by the Trustee from any prior Trustee or the Company, less any amounts properly paid or distributed in accordance with the terms of the applicable trust agreement or otherwise; and

“Trustee” means the trustee appointed from time to time in accordance with the terms of the ACo Trust Agreement or the BCo Trust Agreement, as applicable, which, as of the date hereof, is XXXXXXXXXX, a trust company subsisting under the laws of Canada that is: (i) licensed under the Trust and Loan Companies Act (Canada) (S.C. 1991, c. 45); (ii) a corporation resident in Canada for the purposes of the Act; and (iii) authorized under the laws of Canada or a province to carry on in Canada the business of offering to the public its services as a trustee and that was approved by the NEB to act as a trustee under the ACo Reclamation Trust or the BCo Reclamation Trust.

Our understanding of the statement of facts and proposed transactions is as follows:

STATEMENT OF FACTS

Background

1.    In May 2009, the NEB issued the Reasons for Decision RH-2-2008 Land Matters Consultation Initiative Stream 3 in which it set out principles, a framework and a five-year action plan, with the goal of having all NEB-regulated pipeline companies begin to set aside funds to cover the costs of pipeline abandonment. 

2.    In May 2014, the NEB issued the NEB MH-001-2013 Decision approving the use of a QET as a set-aside mechanism for pipeline abandonment funds. The NEB MH-001-2013 Decision included a model trust agreement and indicative terms for the pipeline companies’ respective trust agreements.

3.    ACo is a taxable Canadian corporation. The address of its head office is XXXXXXXXXX. Its business number is XXXXXXXXXX, its TSO is XXXXXXXXXX and it files its T2 Corporation Income Tax Return with the XXXXXXXXXX Tax Centre.

4.    BCo is a taxable Canadian corporation. The address of its head office is XXXXXXXXXX. Its business number is XXXXXXXXXX, its TSO is XXXXXXXXXX and it files its T2 Corporation Income Tax Return with the XXXXXXXXXX Tax Centre.

5.    BCo L.P. is a Canadian partnership. The address of its head office is XXXXXXXXXX. Its business number is XXXXXXXXXX, its TSO is XXXXXXXXXX and it files its T5013 Partnership Financial Return with the XXXXXXXXXX Tax Centre.

6.    BCo L.P has two partners, ACo and BCo. BCo is the general partner holding XXXXXXXXXX% partnership interest and ACo is the limited partner holding the remainder of the partnership interest. All of the issued and outstanding shares of ACo and BCo are owned by CCo. ACo and BCo are affiliated persons and related persons for the purposes of the Act.

7.    ACo and BCo include all revenues and expenses related to their respective Pipelines in their financial statements and tax returns. Each of ACo and BCo is allocated its respective share of partnership income or loss as a partner of BCo L.P.

8.    ACo holds XXXXXXXXXX issued by the NEB for regulatory authorization to operate the ACo Pipeline. ACo owns and operates the ACo Pipeline. ACo has the obligation to fund the costs relating to the abandonment of the Site of the ACo Pipeline.

9.    BCo is the general partner of BCo L.P. and is the holder of the certificates issued by the NEB for the operation of the BCo Pipeline.

10.   BCo L.P. owns the BCo Pipeline. BCo and BCo L.P. have the obligation to fund the costs relating to the abandonment of the Site of the BCo Pipeline.

11.   The Trustee is a trust company that is:

a.    licensed under the Trust and Loan Companies Act (Canada) (S.C. 1991, c. 45);
b.    a corporation resident in Canada for the purposes of the Act; and

c.    authorized under the laws of Canada or a province to carry on in Canada the business of offering to the public its services as a trustee.

12.   The NEB approved the appointment of the Trustee in its NEB Letter Decision, dated XXXXXXXXXX.

The ACo Trust Agreement and the BCo Trust Agreement

13.   The ACo Reclamation Trust, settled pursuant to the ACo Trust Agreement, is required to be maintained under an order made by the NEB.

14.   A summary of relevant terms of the ACo Trust Agreement is as follows:

a.    The ACo Reclamation Trust is settled as a discretionary trust pursuant to the laws of the Province of XXXXXXXXXX with the express intention to meet the requirements of a QET at all times. The ACo Trust Agreement shall be read and interpreted in light of, and consistently with, the definition of “qualifying environment trust.” All parties involved, shall take (or avoid taking, as the case may be) all actions required to ensure that the ACo Reclamation Trust is a “qualifying environmental trust.” Pursuant to XXXXXXXXXX, the ACo Reclamation Trust is maintained for the sole purpose of funding the Reclamation Obligations with respect to the ACo Pipeline. 

b.    Currently, the Beneficiaries of the ACo Reclamation Trust are ACo and the Orphan Pipeline Fund.

c.    Pursuant to XXXXXXXXXX, funds shall be contributed by ACo to the ACo Reclamation Trust on an annual basis. The Annual Contribution Amount is made pursuant to the National Energy Board Act, R.S.C. 1985, c. N-7, or an order or direction made by the NEB. Contributions made by ACo are irrevocable and cannot revert to ACo except as otherwise provided by the ACo Trust Agreement.

d.    XXXXXXXXXX establishes that the ACo Reclamation Trust is to be administered so that all contributions to, and income or gains realized, shall be used solely to: (i) discharge the Reclamation Obligations with respect to the ACo Pipeline; (ii) compensate the Trustee or its agents for services rendered or expenses incurred in accordance with the ACo Trust Agreement; and (iii) discharge the tax obligations of the ACo Reclamation Trust.

e.    Under XXXXXXXXXX, the Trustee has the power to appoint among the Beneficiaries of the ACo Reclamation Trust, at its discretion, funds from the Trust Fund responding at the time of payment to the then existing Reclamation Obligations of each beneficiary. The Trustee may make payment to or for the benefit of the appointed beneficiary. Before making any discretionary payment, the Trustee must receive the approval of the NEB, which approval will cover both the Reclamation Obligations being addressed and that person or those persons that are instructed to carry out work with respect to such Reclamation Obligations.

f.    The ACo Reclamation Trust shall maintain its situs, mind and management in XXXXXXXXXX as provided in XXXXXXXXXX and will be considered to be a resident of XXXXXXXXXX at all times.

g.    Under XXXXXXXXXX, distributions from the ACo Reclamation Trust to a Beneficiary of the ACo Reclamation Trust or a third party are to be made for the sole purpose of discharging the beneficiary’s Reclamation Obligations. The Trustee may make a distribution after a presentation of a direction or an order by the NEB issued in the name of the beneficiary or the third party, as the case may be. The Trustee shall not make a distribution to a Beneficiary of the ACo Reclamation Trust who has suffered an event of default within the meaning of the ACo Trust Agreement.

h.    In the case of a sale, transfer or other disposition of the ACo Pipeline or a portion thereof, the Trustee may transfer the Trust Fund or a portion thereof to another QET for the purpose of funding Reclamation Obligations in accordance with the ACo Trust Agreement and upon any order or direction from the NEB, including any such direction or order that is made pursuant to paragraphs 74(1)(a), (b) or (c) of the National Energy Board Act, R.S.C. 1985, c. N-7, as provided in XXXXXXXXXX.

i.    Pursuant to XXXXXXXXXX, the Trustee will not borrow money on behalf of the ACo Reclamation Trust at any time.

j.    By virtue of XXXXXXXXXX and in accordance with applicable laws and the Statement of Investment Policies and Procedures, the Trustee will only acquire Qualified Investments and will not hold a “prohibited investment” as this term is defined in subsection 211.6(1).

k.    XXXXXXXXXX provides that the terms of the ACo Reclamation Trust may be modified by the Company and the Trustee by an agreement in writing approved by the NEB, provided that the amendments are consistent with the purposes of the ACo Reclamation Trust as set out in the ACo Trust Agreement.

l.    As provided in XXXXXXXXXX, the ACo Reclamation Trust may not be revoked by its beneficiaries or the Company, acting as a whole, or the Trustee. The NEB, in the exercise of its statutory authority, may direct the termination of the ACo Reclamation Trust and order such successive arrangements as are appropriate in view of fulfilling the purpose of the ACo Reclamation Trust.

m.    Pursuant to XXXXXXXXXX, if property remains in the Trust Fund after all the Reclamation Obligations are discharged, then the Trustee, with the approval of the NEB, may distribute the Trust Fund or any part thereof among any of the Beneficiaries of the ACo Reclamation Trust, including the Orphan Pipeline Fund as the Trustee in its sole discretion sees fit.

15.   The BCo Reclamation Trust, settled pursuant to the BCo Trust Agreement, is required to be maintained under an order made by the NEB.

16.   A summary of relevant terms of the BCo Trust Agreement is as follows:

a.    The BCo Reclamation Trust is settled as a discretionary trust pursuant to the laws of the Province of XXXXXXXXXX with the express intention to meet the requirements of a QET at all times. The BCo Trust Agreement shall be read and interpreted in light of, and consistently with, the definition of “qualifying environment trust.” All parties involved, shall take (or avoid taking, as the case may be) all actions required to ensure that the BCo Reclamation Trust is a “qualifying environmental trust.” Pursuant to XXXXXXXXXX, the BCo Reclamation Trust is maintained for the sole purpose of funding the Reclamation Obligations with respect to the BCo Pipeline.

b.    Currently, the Beneficiaries of the BCo Reclamation Trust are ACo, BCo, BCo L.P. and the Orphan Pipeline Fund.

c.    Pursuant to XXXXXXXXXX, funds shall be contributed by BCo to the BCo Reclamation Trust on an annual basis. The Annual Contribution Amount is made pursuant to the National Energy Board Act, R.S.C. 1985, c. N-7, or an order or direction made by the NEB. Contributions made by BCo are irrevocable and cannot revert to BCo except as otherwise provided by the BCo Trust Agreement.

d.    XXXXXXXXXX establishes that the BCo Reclamation Trust is to be administered so that all contributions to, and income or gains realized, shall be used solely to: (i) discharge the Reclamation Obligations with respect to the BCo Pipeline; (ii) compensate the Trustee or its agents for services rendered or expenses incurred in accordance with the BCo Trust Agreement; and (iii) discharge the tax obligations of the BCo Reclamation Trust.

e.    Under XXXXXXXXXX, the Trustee has the power to appoint, among the Beneficiaries of the BCo Reclamation Trust, at its discretion, funds from the Trust Fund responding at the time of payment to the then existing Reclamation Obligations of each beneficiary. The Trustee may make payment to or for the benefit of the appointed beneficiary. Before making any discretionary payment, the Trustee must receive the approval of the NEB, which approval will cover both the Reclamation Obligations being addressed and that person or those persons that are instructed to carry out work with respect to such Reclamation Obligations.

f.    The BCo Reclamation Trust shall maintain its situs, mind and management in XXXXXXXXXX as provided for in XXXXXXXXXX and will be considered to be a resident of XXXXXXXXXX at all times.

g.    Under XXXXXXXXXX, distributions from the BCo Reclamation Trust to a Beneficiary of the BCo Reclamation Trust or a third party are to be made for the sole purpose of discharging the beneficiary’s Reclamation Obligations. The Trustee may make a distribution after a presentation of a direction or an order by the NEB issued in the name of the beneficiary or the third party, as the case may be. The Trustee shall not make a distribution to a Beneficiary of the BCo Reclamation Trust who has suffered an event of default within the meaning of the BCo Trust Agreement.

h.    In the case of a sale, transfer or other disposition of the BCo Pipeline or a portion thereof, the Trustee may transfer the Trust Fund or a portion thereof to another QET for the purpose of funding Reclamation Obligations in accordance with the BCo Trust Agreement and upon any order or direction from the NEB, including any such direction or order that is made pursuant to paragraphs 74(1)(a), (b) or (c) of the National Energy Board Act, R.S.C. 1985, c. N-7, as provided in XXXXXXXXXX.

i.    Pursuant to XXXXXXXXXX, the Trustee will not borrow money on behalf of the BCo Reclamation Trust at any time.

j.    By virtue of XXXXXXXXXX and in accordance with applicable laws and the Statement of Investment Policies and Procedures, the Trustee will only acquire Qualified Investments and will not hold a “prohibited investment” as this term is defined in subsection 211.6(1).

k.    XXXXXXXXXX provides that the terms of the BCo Reclamation Trust may be modified by the Company and the Trustee by an agreement in writing approved by the NEB, provided that the amendments are consistent with the purposes of the BCo Reclamation Trust as set out in the BCo Trust Agreement.

l.    As provided in XXXXXXXXXX, the BCo Reclamation Trust may not be revoked by its beneficiaries or the Company, acting as a whole, or the Trustee. The NEB, in the exercise of its statutory authority may, direct the termination of the BCo Reclamation Trust, and order such successive arrangements as are appropriate in view of fulfilling the purpose of the BCo Reclamation Trust.

m.    Pursuant to XXXXXXXXXX, if property remains in the Trust Fund after all the Reclamation Obligations are discharged, then the Trustee, with the approval of the NEB, may distribute the Trust Fund or any part thereof among any of the Beneficiaries of the BCo Reclamation Trust, including the Orphan Pipeline Fund, as the Trustee in its sole discretion sees fit.

PROPOSED TRANSACTIONS

17.   The following transactions will be undertaken in accordance with the terms of the ACo Trust Agreement and the BCo Trust Agreement, and in compliance with the relevant decisions, orders and directions of the NEB:

a.    Commencing in the XXXXXXXXXX taxation year, ACo will make contributions to the ACo Reclamation Trust for the purpose of funding the Reclamation Obligations in respect of the Site of the ACo Pipeline.

b.    Commencing in the XXXXXXXXXX taxation year, BCo L.P. will make contributions to the BCo Reclamation Trust for the purpose of funding the Reclamation Obligations in respect of the Site of the BCo Pipeline.

c.    At all times, the respective Trust Funds will be invested in accordance with the applicable Statement of Investment Policies and Procedures. The ACo Reclamation Trust and the BCo Reclamation Trust will not borrow money at any time, and will only invest in property that is a Qualified Investment. Initially the Trust Funds have been invested in debt securities issued by the Government of Canada or by a government of a province.

PURPOSE OF PROPOSED TRANSACTIONS

The purpose of the proposed transactions is to set aside funds for the sole purpose of funding the reclamation of a “qualifying site,” as that term is defined in subsection 211.6(1), through a mechanism that qualifies as a QET under the Act and that is in compliance with the NEB decisions, orders and directions applicable to any of ACo, BCo and BCo L.P.

RULINGS

Provided that the preceding statements constitute a complete and accurate disclosure of all the relevant facts, proposed transactions and purpose of the proposed transactions, and provided that the proposed transactions are carried out as described above, we rule as follows:

A.    Provided that the ACo Reclamation Trust is operated in accordance with the terms of the ACo Trust Agreement, the ACo Reclamation Trust will constitute a “qualifying environmental trust” as that term is defined in subsection 211.6(1).

B.    Amounts contributed by ACo to the ACo Reclamation Trust will be deductible in computing the income of ACo pursuant to paragraph 20(1)(ss), provided that the ACo Reclamation Trust continues to qualify as a qualifying environmental trust at the time of the contribution.

C.    In computing the income, non-capital loss and net capital loss of ACo, for the purposes of applying subsection 107.3(1), the entire amount of any income or loss of the ACo Reclamation Trust for any taxation year of the trust that ends in a particular taxation year of ACo can reasonably be considered to be ACo’s share of such income or loss.

D.    Provided that the BCo Reclamation Trust is operated in accordance with the terms of the BCo Trust Agreement, the BCo Reclamation Trust will constitute a “qualifying environmental trust” as that term is defined in subsection 211.6(1).

E.    Amounts contributed by BCo L.P. to the BCo Reclamation Trust will be deductible pursuant to paragraph 20(1)(ss) in computing the income of BCo L.P. for a taxation year, provided that BCo Reclamation Trust continues to qualify as a qualifying environmental trust at the time of the contribution.

F.    In computing the income, non-capital loss and net capital loss of BCo L.P., for the purposes of applying subsection 107.3(1), the entire amount of any income or loss of the BCo Reclamation Trust for any taxation year of the trust that ends in a particular fiscal period of BCo L.P. can reasonably be considered to be BCo L.P.’s share of such income or loss.

G.    Each of BCo and ACo will be entitled to deduct from its tax otherwise payable under Part I of the Act for a taxation year the amount that can reasonably be considered to be its respective share of the Part XII.4 tax credit in respect of BCo L.P. in accordance with section 127.41.

H.    A debt obligation that meets the definition of “qualified investment” in paragraph (b) of section 204 will not be a “prohibited investment” of the ACo Reclamation Trust or the BCo Reclamation Trust for the purpose of the definition of that term in subsection 211.6(1).

Comments

Except as expressly stated, the rulings provided do not imply acceptance, approval or confirmation of any income tax implications of the facts or proposed transactions. In particular, nothing in this letter should be interpreted as confirming either expressly or implicitly:

a.    the reasonableness of any expenditure referred to in this letter;

b.    the person or persons subject to tax on funds distributed by the ACo Reclamation Trust or the BCo Reclamation Trust;

c.    whether the ACo Reclamation Trust or the BCo Reclamation Trust is a valid trust at law; and

d.    the application of any perpetuity legislation to the ACo Reclamation Trust and the BCo Reclamation Trust.

The above rulings are given subject to the limitations and qualifications set out in Information Circular 70-6R6 dated August 29, 2014, and are binding on the Canada Revenue Agency provided that the proposed transactions are implemented as described above. For greater certainty, these advance income tax rulings are based on the ACo Trust Agreement and the BCo Trust Agreement as amended on XXXXXXXXXX and approved by the NEB on XXXXXXXXXX. If amendments to the aforementioned trust agreements are made after that time, the rulings provided may not apply unless the amendment is approved by the NEB and a supplemental ruling is issued.

These rulings are based on the law as it presently reads and do not take into account any proposed amendments to the Act which, if enacted, could have an effect on the rulings provided herein.

Yours truly,

XXXXXXXXXX
Manager
Resources Section
Reorganizations Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch

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