2001 Income Tax Severed Letter 2001-0076821 - XXXXXXXXXX

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department.

Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère.

Principal Issues:

This supplemental ruling to file #2000-006135 involves a XXXXXXXXXX . Would certain minor factual changes alter the rulings or opinions previously given?

Position:

No.

Reasons:

Only minor changes made. No issues raised as a result of the changes.

XXXXXXXXXX 2001-007682

XXXXXXXXXX, 2001

Dear XXXXXXXXXX:

Re: Supplementary Advance Income Tax Ruling Request
XXXXXXXXXX (the "General Partner")
XXXXXXXXXX (the "Partnership")

This is in reply to your letter dated XXXXXXXXXX, wherein you requested confirmation that certain changes to the Facts and Proposed Transactions in the advance income tax ruling we issued to the General Partner, dated XXXXXXXXXX, 2001 (our file number 2000-006135, hereinafter referred to as the "Ruling"), would not affect the rulings and opinions given therein. You advise that the transactions described in the Ruling are still proposed and that it is intended that the first subscription for units of the Partnership will take place on XXXXXXXXXX.

In addition to some minor factual changes, you advise that Mr. V, Mr. W, and Mr. Y have disposed of their shares in Aco and Manager, as was contemplated in paragraph 11 of the Facts to the Ruling. Consequently, you have requested the following amendments to the Ruling:

1. Add the following three definitions to the Definitions section of the Ruling:

"Advisor" means XXXXXXXXXX.

"Advisorco" means XXXXXXXXXX.

"Agent" means XXXXXXXXXX.

2. Replace the definition of "Bco" with "Bco" means XXXXXXXXXX.

3. Replace the definition of "Cco" with "Cco" means XXXXXXXXXX.

4. Delete the following definitions from the Definitions section of the Ruling:

"Dco"; "Mr. V"; "Ms. V"; "Mr. W"; "Ms. W"; and "Mr. Y".

5. Replace paragraph 4 of the Ruling with

Manager is a corporation incorporated under the federal laws of Canada on XXXXXXXXXX. Agent is a corporation incorporated under the laws of the province of XXXXXXXXXX. Both Manager and Agent are wholly- owned by Cco. Cco is a corporation incorporated under the federal laws of Canada on XXXXXXXXXX, and is owned as to XXXXXXXXXX% by Advisorco and as to XXXXXXXXXX% by Gco. Advisorco is a corporation incorporated under the laws of XXXXXXXXXX. All of the shares of Advisorco are owned by Advisor, a resident of XXXXXXXXXX.

6. Replace paragraph 6 of the Ruling with

Aco is a corporation incorporated under the federal laws of Canada on XXXXXXXXXX. Aco is wholly-owned by Gco.

7. Delete the last two sentences in paragraph 11.

8. In paragraph 24, replace the reference to "XXXXXXXXXX%" with "XXXXXXXXXX%".

We confirm that the above changes have been made and the balance of the Ruling remains unchanged.

Yours truly,

XXXXXXXXXX
for Director
Business and Partnerships Division
Income Tax Rulings Directorate
Policy and Legislation Branch