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THE DEDUCTION OF FINANCING EXPENSES …

4674538 v9 THE DEDUCTION OF FINANCING EXPENSES OTHER THAN interest Ron Durand Stikeman Elliott LLP June 3, 20104674538 v9 ( i ) THE DEDUCTION OF FINANCING EXPENSES OTHER THAN interest INDEX 20(1)(e) - FINANCING EXPENSES ..1 Timing of the Expense ..4 Timing of the DEDUCTION ..5 Who may Deduct ..5 Repayment ..6 Dissolution of Partnership ..7 Amalgamation and Wind-up ..7 Discount or Fee for Underwriting ..7 Participation Payments ..8 Currency Hedge ..9 Warrants ..10 Guarantees ..10 Environmental Approval ..10 20(1)( ) - Annual Fees ..11 Interaction of Paragraphs 20(1)(e) and 20(1)( ) ..11 Annual Basis ..12 20(1)( ) - Insurance Premiums ..12 Treatment Prior to Paragraph 20(1)( ) ..12 Current Proration ..14 Relation to Amount Owing ..14 4674538 v9 ( ii ) 18( ) - Penalties, Bonuses and Rate-Reduction Payments ..15 Timing of DEDUCTION ..16 Exclusions ..17 SELECTED BIBLIOGRAPHY ..18 Paragraph 20(1)(e).

4674538 v9 THE DEDUCTION OF FINANCING EXPENSES OTHER THAN INTEREST Ron Durand Stikeman Elliott LLP June 3, 2010

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  Interest, Expenses, Financing, Deduction, The deduction of financing expenses

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