Proftitcos will form an LP to facilitate the transfer of losses from a multitude of sister losscos

In order to facilitate the transfer of losses between a multitude of subsidiary Losscos and three Profitcos (being the parent and two wholly-owned subsidiaries), the Profitcos will form a subsidiary LP which will subscribe for pref of the Losscos and receive interest-bearing loans from the Losscos.

Neal Armstrong. Summary of 2013 Ruling 2012-0458091R3 under s. 111(1)(a).