2001 2001-0080891 - reorganization, change in facts

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: change of facts, no new issues

Position:

Reasons:

XXXXXXXXXX 2001-008089

XXXXXXXXXX, 2001

Dear XXXXXXXXXX:

Re: Advance income tax ruling #2000-004996
dated XXXXXXXXXX, 2001 issued to XXXXXXXXXX
(the "Ruling Letter")

We are writing in response to your telephone call of XXXXXXXXXX wherein you advised us of certain changes to the facts and proposed transactions described in the Ruling Letter. As a result, the following changes are made:

1. The portion of paragraph 34 before (a) will be changed to "After completion of the proposed transactions except for the amalgamations described in paragraphs 29 to 32 above,"

2. Subparagraph 35(c) will be changed to "the transactions set out in paragraphs 28 to 32 will occur following the transactions described in (b) above, except for the amalgamations described in paragraphs 29 to 32 above which will occur effective XXXXXXXXXX.

3. The last sentence of the Rulings Provided section will be changed to "The above rulings are given subject to the limitations and qualifications set out in Information Circular 70-6R4 dated January 29, 2001 issued by the Canada Customs and Revenue Agency (the "CCRA") and are binding on the CCRA provided the proposed transactions described herein, except for the amalgamations described in paragraphs 29 to 32 above, are completed by XXXXXXXXXX and the amalgamations described in paragraphs 29 to 32 above are completed effective XXXXXXXXXX."

You have advised us that there have not been any other changes to the relevant facts and proposed transactions described in the Ruling Letter. Subject to the conditions stated therein, the Ruling Letter will continue to be binding on the Canada Customs and Revenue Agency provided that the proposed transactions are completed by the dates described in paragraph 3 above.

Yours truly,

for Director
Reorganizations and Resources Division
Income Tax Rulings Directorate
Policy and Legislation Branch