Principal Issues: 1) Whether paragraph 84.1(1)(b) applies to the proposed post-mortem pipeline transactions; 2) Whether subsection 84(2) applies to the proposed post-mortem pipeline transactions.
Position: 1) No; 2) No.
Reasons: 1) Non-share consideration does not exceed the adjusted cost base of the transferred shares; 2) In accordance with the Act and consistent with CRA's published positions.
Principal Issues: Whether the ITRD could provide comments concerning the application of the definition of "participating debt interest" in subsection 212(3) to a Model Convertible Promissory Note?
Position: No.
Reasons: The ITRD does not provide confirmation concerning the tax consequences of convertible debts based on model contracts in the context of technical interpretations.
