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 CCRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ADRC.
Principal Issues: Whether (i) Subsection 85.1(3) applies to disposition of shares held by Pubco to FA1 ("Settled Property"); (ii) pursuant to a trust established by a Deed of Settlement of the Settled Property, that trust as established will, except for purposes of subsections 104(1), 104(1.1) and subparagraphs (b)(v) and (k) of the definition of "disposition" in subsection 248(1) of the Income Tax Act (the "Act"), not be a trust for purposes of the Act; (iii) provided XXXXXXXXXX is a partnership at law, income derived by FA1 and FA2 from amounts paid or payable to XXXXXXXXXX by Opco in accordance with the Profit Transfer Agreement will be included in computing active business income of FA1 and FA2 pursuant to clause 95(2)(a)(ii)(B); (iv) income derived by Lenderco from interest paid or payable by XXXXXXXXXX under the XXXXXXXXXX Loan will be included in computing income from active business and in computing the exempt earnings of Lenderco to the extent that such interest would be deductible in the year or a subsequent year in computing the amounts that would be prescribed to be the earnings (not a loss) from an active business of XXXXXXXXXX other than an active business carried on in Canada if XXXXXXXXXX were a foreign affiliate of Pubco; (v) GAAR will apply to proposed transactions.
Position: (i) Yes; (ii) Yes; (iii) Yes; (iv) Yes; (v) No.
Reasons: (i) conditions in subsection 85.1(3) satisfied; (ii) provided Pubco acts as agent for FA1 with respect to all dealings with all of the Trust Property, as set out in the Deed of Settlement; (iii) the Opco payment to XXXXXXXXXX under the Profit Transfer Agreement would be income from property as it is derived from shares held in Opco; consequently, clause 95(2)(a)(ii)(B) can apply to re-characterize this income from property and include it in computing the exempt earnings of FA1 and FA2 pursuant to clause (d)(ii)(E) of that definition in subsection 5907(1) of the Regulations, to the extent the amounts paid or payable by Opco to XXXXXXXXXX under the Profit Transfer Agreement can be considered deductible in the year or a subsequent taxation year in computing the amounts prescribed to be the exempt earnings or exempt loss from an active business of Opco other than an active business carried on in Canada; (iv) because if XXXXXXXXXX were a foreign affiliate of Pubco, Canco would have a qualifying interest in XXXXXXXXXX and its income would be re-characterized under subparagraph 95(2)(a)(ii) so that the payment to Lenderco would be deductible in computing such income; (v) no avoidance transaction.
XXXXXXXXXX 2001-011123
XXXXXXXXXX, 2003
Dear XXXXXXXXXX:
Re: Advance Income Tax Ruling
XXXXXXXXXX ("Pubco") (XXXXXXXXXX)
This is in reply to your letters of XXXXXXXXXX, requesting an advance income tax ruling on behalf of the above-noted taxpayer. We also acknowledge the amendments to the proposed transactions and the additional information provided in various subsequent letters, emails, facsimiles and telephone conversations (XXXXXXXXXX).
Our understanding of the facts, proposed transactions and purpose of the proposed transactions is as follows:
Definitions
In this ruling, unless otherwise specified:
? "Act" means the Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.), as amended to the date hereof;
? "Regulations" means the Income Tax Regulations, C.R.C. 1977, c. 945, as amended to the date hereof;
? all statutory references herein are to provisions of the Act unless otherwise specified;
? the words and expressions which are defined for purposes of the Act and Regulations (in particular, subdivision i of Division B of Part I of the Act and Part LIX of the Regulations) shall have the same meanings for the purposes hereof;
? "Proposed Transactions" means the transactions described in the paragraphs hereof which appear under the heading "Proposed Transactions";
? XXXXXXXXXX is "Pubco";
? XXXXXXXXXX is "Canco 1";
? XXXXXXXXXX is "Canco 2";
? XXXXXXXXXX is "Lenderco";
? XXXXXXXXXX is "Holdco 1";
? XXXXXXXXXX is "Holdco 2";
? XXXXXXXXXX is "Finco";
? XXXXXXXXXX is "Opco".
Facts
1. Pubco is a widely held Canadian public company, which carries on an XXXXXXXXXX business both in Canada and abroad, both directly and indirectly through subsidiaries and other affiliates. Pubco is a public corporation and a taxable Canadian corporation.
2. Canco 1 is a direct wholly owned subsidiary of Pubco and a taxable Canadian corporation.
3. Lenderco is a XXXXXXXXXX corporation, with its central control and management in XXXXXXXXXX, which is resident in XXXXXXXXXX for the purposes of the Canada XXXXXXXXXX Income Tax Convention, and is a direct wholly owned subsidiary of Pubco. Lenderco is a foreign affiliate and a controlled foreign affiliate of Pubco in respect of which Pubco has a qualifying interest.
4. Holdco 1 is a XXXXXXXXXX corporation, with its central control and management in XXXXXXXXXX, which is resident in XXXXXXXXXX for the purposes of the Canada-XXXXXXXXXX Income Tax Convention, and is an indirect wholly-owned subsidiary of Pubco. Holdco 1 is a wholly owned subsidiary of Canco 1. Holdco 1 is a foreign affiliate and a controlled foreign affiliate of Canco 1 (and of Pubco) in respect of which Canco 1 (and Pubco) has a qualifying interest.
5. Finco is an XXXXXXXXXX corporation, with its central control and management in XXXXXXXXXX, which is resident in XXXXXXXXXX for the purposes of the Canada-XXXXXXXXXX Income Tax Convention, and is a direct wholly owned subsidiary of Canco 2. Finco is engaged in providing financing to various non-resident corporations controlled directly or indirectly by Pubco. Finco is a foreign affiliate and a controlled foreign affiliate of Canco 2 (and of Canco 1 and Pubco) in respect of which Canco 2 (and Canco 1 and Pubco) has a qualifying interest. Canco 2 is a taxable Canadian corporation, which is a direct wholly owned subsidiary of Canco 1 and, therefore, an indirect wholly owned subsidiary of Pubco.
6. Opco is a XXXXXXXXXX with its central control and management in XXXXXXXXXX, which is resident in XXXXXXXXXX for the purposes of the Canada-XXXXXXXXXX Income Tax Convention, and is an indirect wholly owned subsidiary of Pubco. Opco is engaged in the XXXXXXXXXX business in XXXXXXXXXX. Opco is a foreign affiliate and a controlled foreign affiliate of Pubco in respect of which Pubco has a qualifying interest. For the purposes of paragraph 5906(1)(a) of the Regulations, Opco carries on an active business only in XXXXXXXXXX. All or substantially all of Opco's assets constitute excluded property, consisting of assets used or held by it principally for the purpose of gaining or producing income from an active business.
7. Opco borrowed money from Finco and used the proceeds thereof in its active business (the "Existing Loan(s)").
8. Before XXXXXXXXXX, Pubco acquired from Holdco 1 all of the Opco shares (being XXXXXXXXXX% of Opco's shares) which were owned by Holdco 1, in consideration for XXXXXXXXXX Before XXXXXXXXXX, Pubco acquired from Holdco 2, in the course of the liquidation and dissolution of Holdco 2, all of the Opco shares (being XXXXXXXXXX% of Opco's shares) which were owned by Holdco 2. Holdco 2 was a XXXXXXXXXX corporation, with its central control and management in XXXXXXXXXX, which was resident in XXXXXXXXXX for the purposes of the Canada-XXXXXXXXXX Income Tax Convention, and was a direct wholly owned subsidiary of Pubco. Holdco 2 was a foreign affiliate and a controlled foreign affiliate of Pubco in respect of which Pubco had a qualifying interest.
9. Before XXXXXXXXXX, Pubco acquired all but one (i.e., XXXXXXXXXX) of the issued and outstanding shares of a new XXXXXXXXXX corporation ("FA1"); Finco acquired the remaining share of FA1. Pubco also acquired all of the issued and outstanding shares of a new XXXXXXXXXX ("FA2"). FA1 and FA2 each have issued one class of shares. The central control and management of FA1 is and will be in XXXXXXXXXX, and FA1 is and will be resident in XXXXXXXXXX for the purposes of the Canada-XXXXXXXXXX Income Tax Convention. The central control and management of FA2 is and will be in XXXXXXXXXX, and FA2 is and will be resident in XXXXXXXXXX for the purposes of the Canada-XXXXXXXXXX Income Tax Convention. Each of FA1 and FA2 is and will be a foreign affiliate and a controlled foreign affiliate of Pubco in respect of which Pubco has a qualifying interest.
10. Before XXXXXXXXXX, Pubco transferred XXXXXXXXXX% of the issued and outstanding shares in Opco to FA1 in exchange for shares of FA1.
11. Before XXXXXXXXXX, FA1 and FA2 formed, in accordance with the applicable articles of the XXXXXXXXXX an association designated as a "XXXXXXXXXX" (the "XXXXXXXXXX"). FA1 contributed to the XXXXXXXXXX XXXXXXXXXX% of the issued and outstanding shares in Opco, in exchange for an entitlement to approximately XXXXXXXXXX% of the income of the XXXXXXXXXX, without liability for the obligations of the XXXXXXXXXX exceeding the amount of its contribution. FA2 contributed an amount in Euros (approximately XXXXXXXXXX) to the XXXXXXXXXX, in exchange for an entitlement to approximately XXXXXXXXXX% of the income of the XXXXXXXXXX, with unlimited liability for the obligations of the XXXXXXXXXX. FA2 has full and exclusive management authority and responsibility in respect of the activities of the XXXXXXXXXX. For XXXXXXXXXX corporation tax purposes, the XXXXXXXXXX is treated as a partnership and, as such, is required to compute its income and capital gains (or losses) at the XXXXXXXXXX level, but it is FA1 and FA2, being the partners, which are and will be required to pay any XXXXXXXXXX tax liabilities arising in respect of the XXXXXXXXXX income and capital gains (or losses) in accordance with their respective interests in the XXXXXXXXXX.
12. Pursuant to the provisions of the XXXXXXXXXX has the following salient characteristics:
a. The XXXXXXXXXX is an association formed by the mere agreement of FA1 and FA2 to carry on commercial activity in common for profit, and to make their respective contributions.
b. No government executive or other action was required for the formation of the XXXXXXXXXX, but limited liability was conferred on FA1 upon registration of the XXXXXXXXXX.
c. The assets and liabilities of the XXXXXXXXXX are the joint assets and several liabilities of its members (subject to limited liability in favour of members with limited liability (i.e., FA1)).
d. The XXXXXXXXXX can sue and be sued in its firm name, but does not otherwise have a separate legal personality that is distinct from those of its members.
e. The members of the XXXXXXXXXX have and continue to have a reasonable expectation that the activities of the XXXXXXXXXX will yield a profit.
f. The agreement governing the XXXXXXXXXX provides that the profits and losses of the XXXXXXXXXX are and continue to be allocated among its members in accordance with their respective interests in the XXXXXXXXXX.
13. On or before XXXXXXXXXX, Opco paid a dividend (the "Dividend") on its issued and outstanding shares, in an amount that approximated its retained earnings. The XXXXXXXXXX received XXXXXXXXXX percent, and Pubco received XXXXXXXXXX percent, of the Dividend.
14. On or before XXXXXXXXXX, senior executives and other management personnel of Opco were transferred to, and thereupon became employed by, the XXXXXXXXXX. Such personnel actively managed the day-to-day operations and other activities of Opco, as employees of the XXXXXXXXXX. One of these executives was appointed as the managing director of FA2.
15. On XXXXXXXXXX, Opco repaid to Finco part of the Existing Loan(s), and Finco used the proceeds of that repayment to make a loan to Lenderco (the "Lenderco Loan"), which used the proceeds of that loan to make a loan to the XXXXXXXXXX (the "XXXXXXXXXX Loan"), which used the proceeds thereof to make a contribution to the capital of Opco. Interest is payable by the XXXXXXXXXX to Lenderco under the XXXXXXXXXX Loan, and by Lenderco to Finco under the Lenderco Loan.
16. The taxation year-end of Pubco, Canco 1, Canco 2, Lenderco, Holdco 1, Holdco 2, FA1, FA2, Finco and Opco is XXXXXXXXXX respectively.
17. Pubco, Canco 1 and Canco2 have not filed their tax returns in Canada for their taxation year ended XXXXXXXXXX.
Proposed Transactions
18. On XXXXXXXXXX, Opco and the XXXXXXXXXX entered into a "profit transfer agreement" (the "Profit Transfer Agreement") XXXXXXXXXX Pursuant to the Profit Transfer Agreement, and in accordance with the applicable provisions of the XXXXXXXXXX, any and all income or capital gains arising from the business operations of Opco or from the disposition of Opco's assets (computed in accordance with commercial accounting principles applicable in XXXXXXXXXX) is and will continue to be transferred to the XXXXXXXXXX, and the XXXXXXXXXX is and will continue to become liable without limitation to compensate Opco for any and all losses arising from the operation or disposition of Opco's assets. The Profit Transfer Agreement has effect throughout the year XXXXXXXXXX, and thereafter, in accordance with its terms.
19. For XXXXXXXXXX corporation tax purposes, the relationship between XXXXXXXXXX and Opco constitutes an "XXXXXXXXXX", such that Opco has no income or capital gains (or losses), and any and all income or capital gains (or losses) arising from the operation of Opco's business or disposition of Opco's assets for each of its taxation years is and will continue to be included (or deducted) in the hands of the XXXXXXXXXX, as income or capital gains (or losses) of the XXXXXXXXXX (and not of Opco) from the same sources, and from sources in the same places, in the hands of the XXXXXXXXXX as they would have in the hands of Opco but for the Profit Transfer Agreement.
20. Before XXXXXXXXXX, Pubco will dispose of the entirety of its beneficial interest in the remaining XXXXXXXXXX% of the Opco shares (the "Settled Property") in favour of and for the sole benefit of FA1 in consideration for fully paid non-assessable FA1 shares (the "Disposition"). Pursuant to a trust established by a Deed of Settlement, Pubco will declare that it will thereafter irrevocably hold legal title to the Settled Property and to any income or other benefits derived from, or from the disposition of the Settled Property, or from the investment or reinvestment thereof (the "Trust Property") on behalf of FA1. Pubco will have no authority to enter into any transactions or do any acts in the administration or the investment and management or the disposition of the Trust Property other than in accordance with any specific instructions from FA1, including any instructions to dispose of the whole or any part of the Trust Property in any manner and to any person (other than a distribution to FA1), or to a trust of which FA1 is one of the beneficiaries, for such consideration or for no consideration, and on such terms and conditions as FA1 determines. FA1 may appoint additional or substitutional trustees at any time and for any reason it considers sufficient. On the termination of the Deed of Settlement, any Trust Property then remaining will be paid or applied to or for the exclusive benefit of FA1. The validity of the Deed of Settlement and the provisions thereof shall be governed by the laws of the Province of XXXXXXXXXX.
21. For the purposes of the XXXXXXXXXX, Pubco will continue to be regarded as the owner of the Opco shares disposed of by Pubco to FA1 in accordance with the Deed of Settlement described in paragraph 20 above. As such, Pubco will not be regarded as an "outside shareholder" for the purposes of the XXXXXXXXXX. Neither Opco nor the XXXXXXXXXX will or would, as such, be required to make any compensation payment to Pubco in respect of the earnings of Opco pursuant to the XXXXXXXXXX or any other laws of XXXXXXXXXX. Moreover Opco could not be compelled to make such compensation payment at the request of Pubco.
22. For XXXXXXXXXX corporations tax purposes, interest payable by the XXXXXXXXXX to Lenderco under the XXXXXXXXXX Loan will be deductible by it in computing its income or loss from the operation of Opco's assets.
Purpose of the Proposed Transactions
The purpose of the series of transactions described above in paragraphs 9 through 22 above is to restructure part of the existing indebtedness of Opco in order to allow all of the interest on the money borrowed by XXXXXXXXXX and Opco to be deducted for XXXXXXXXXX income tax purposes where the deduction would have otherwise been limited.
To the best of your knowledge and that of the taxpayers involved, none of the issues involved with this ruling letter:
(i) is under objection;
(ii) is before the courts or, if a judgment has been issued, the time limit for appeal has not expired;
(iii) is involved in an earlier return of one of the taxpayers or a related person; or
(iv) is being considered by a tax services office or a taxation centre in connection with a tax return already filed by one of the taxpayers or a related person.
Rulings Given
Provided that the preceding statements constitute a complete and accurate disclosure of all of the relevant facts, proposed transactions, purpose of the proposed transactions and additional information, and provided that the XXXXXXXXXX is a partnership for purposes of the Act, our rulings are as follows:
A. Subsection 85.1(3) will apply to the Disposition described above in paragraph 20 such that the proceeds of disposition to Pubco, and the cost to FA1, of the Opco shares, as well as the cost to Pubco of the FA1 shares acquired by it as consideration therefore, will be equal to the total of the adjusted cost bases to Pubco of such Opco shares immediately before the Disposition, provided the Disposition is not part of a series of transactions or events for the purpose of disposing of the Opco shares to a person who was immediately after the series of transactions or events a person (other than a foreign affiliate of Pubco) with whom Pubco was dealing at arm's length.
B. Provided Pubco acts as agent for FA1 with respect to all dealings with all of the Trust Property as set out in the Deed of Settlement described in paragraph 20 above, unless the trust established by the Deed of Settlement is described in any of paragraphs (a) to (e.1) of the definition of "trust" in subsection 108(1), it will, except for purposes of subsection 104(1), subsection 104(1.1), subparagraph (b)(v) and paragraph (k) of the definition of "disposition" in subsection 248(1), be deemed not to be a trust for purposes of the Act.
C. To the extent that such income would otherwise be income from property, the income derived by FA1 and FA2 from amounts paid or payable to XXXXXXXXXX by Opco in accordance with the Profit Transfer Agreement will in relation to Pubco be included in computing the income from an active business of FA1 and FA2 pursuant to clause 95(2)(a)(ii)(B) and will be included in computing the exempt earnings of FA1 and FA2 in relation to Pubco pursuant to clause (d)(ii)(E) of that definition in subsection of 5907(1) of the Regulations, in accordance with their respective interests in the XXXXXXXXXX, to the extent that the amounts that are paid or payable by Opco to the XXXXXXXXXX under the Profit Transfer Agreement are deductible in the year or a subsequent taxation year in computing the amounts prescribed to be the exempt earnings or exempt loss from an active business of Opco, other than an active business carried on in Canada. For these purposes, the amounts that are paid or payable will be considered to be deductible for that year in computing the amounts prescribed to be exempt earnings or exempt loss from an active business of Opco, other than an active business carried on in Canada, to the extent that, before taking into account any such payments, Opco has an amount of "exempt earnings" for that year from an active business, other than an active business carried on in Canada, as defined in subsection 5907(1) of the Regulations, which equals or exceeds the amount of any such payments.
D. To the extent that such income would otherwise be income from property, the income derived by Lenderco from amounts paid as interest to Lenderco by the XXXXXXXXXX under the XXXXXXXXXX Loan will be included in computing the income from an active business of Lenderco vis-à-vis Pubco pursuant to clause 95(2)(a)(ii)(B), and will be included in computing the exempt earnings of Lenderco vis-à-vis Pubco pursuant to clause (d)(ii)(F) of that definition in subsection 5907(1) of the Regulations, to the extent that the amounts that are paid by the XXXXXXXXXX to Lenderco under the XXXXXXXXXX Loan are deductible in the year or a subsequent taxation year in computing the amounts that would be prescribed to be the exempt earnings from an active business of the XXXXXXXXXX, other than an active business carried on in Canada, if the XXXXXXXXXX were a foreign affiliate of Pubco.
These amounts would include income which would otherwise be income from property derived by the XXXXXXXXXX from amounts paid or payable to the XXXXXXXXXX by Opco in accordance with the Profit Transfer Agreement, to the extent that those amounts are deductible in the year or a subsequent taxation year in computing the amounts prescribed to be the exempt earnings or exempt loss from an active business of Opco, other than an active business carried on in Canada.
E. As a result of the Proposed Transactions, in and by themselves, subsection 245(2) will not be applied to redetermine the tax consequences described in the rulings given above.
The above rulings are based on the Act in its present form and do not take into account any proposed amendments to the Act.
The above rulings are given subject to the limitations and qualifications set out in Information Circular 70-6R5 dated May 17, 2002, issued by the Canada Customs and Revenue Agency ("the CCRA") and are binding on the CCRA.
The income of Lenderco vis-à-vis Canco 2 is income from property for the reason that Canco 2 does not have a "qualifying interest" as defined in paragraph 95(2)(m) in Lenderco. As a result, the income of Finco derived from interest paid or payable under the Lenderco Loan does not qualify for re-characterization as active business income under the provisions of paragraph 95(2)(a). However, provided that the legislative proposals introduced by the Department of Finance December 20, 2002 (the "Legislative Proposals") are enacted into law as currently worded, it is our opinion that proposed paragraph 95(2)(n) will apply to deem Lenderco to be a foreign affiliate of Canco 2 in respect of which Canco 2 has a qualifying interest. Accordingly, provided the Legislative Proposals are enacted into law as they are currently worded, in our opinion to the extent that such income would otherwise be income from property, the income derived by Finco from interest paid to Finco by Lenderco under the Lenderco Loan will be included in computing the income from an active business of Finco pursuant to clause 95(2)(a)(ii)(B), and will be included in computing the exempt earnings of Finco pursuant to clause (d)(ii)(E) of that definition in subsection of 5907(1) of the Regulations, to the extent that the amounts that are paid by Lenderco to Finco under the Lenderco Loan are deductible in the year or a subsequent taxation year in computing the amounts that would be prescribed to be the exempt earnings from an active business of Lenderco other than an active business carried on in Canada. These amounts would include income derived by Lenderco from interest paid or payable to Lenderco by the XXXXXXXXXX in accordance with the XXXXXXXXXX Loan that is included in computing the exempt earnings of Lenderco in accordance with Ruling D above.
Under the provisions of paragraph 95(2)(a)(ii) and the definition of "loss" and "exempt loss" in subsection 5907(1) of the Regulations as currently worded, Ruling D above and the preceding comment will only apply if XXXXXXXXXX or Lenderco as the case may be, has positive earnings from an active business (i.e. after the deduction of applicable interest on the XXXXXXXXXX Loan or the Lenderco Loan as the case may be). However, provided the proposed amendments to paragraph 95(2)(a)(ii) and the definition of "loss" and "exempt loss" in subsection 5907(1) of the Regulations included in the Legislative Proposals are enacted into law as currently worded, it is our opinion that Ruling D and the preceding comment will also apply if the interest paid on the XXXXXXXXXX Loan or the Lenderco Loan as the case may be would be deductible in computing the amount that would be prescribed to be the "exempt loss" of the XXXXXXXXXX if the XXXXXXXXXX were a foreign affiliate of Pubco or in computing the amount prescribed to be the "exempt loss" of Lenderco as the case may be.
Nothing in this letter shall be construed as implying that the CCRA has accepted or otherwise agreed:
(a) to the determination of the amount of the adjusted cost base of any property referred to herein or the fair value of any assets transferred;
(b) to the validity of any agreements or terms and conditions therein;
(c) to surplus balances of foreign affiliates referred to herein;
(d) that the general anti-avoidance rule will not apply to completed or future transactions other than the Proposed Transactions as described in this letter;
(e) subsection 56(2) will not apply to include in computing Pubco's income, an amount in respect of 10% of the whole amount transferred by Opco to the XXXXXXXXXX under the Profit Transfer Agreement in respect of Opco's taxation year ended XXXXXXXXXX;
(f) with respect to Ruling B, that a trust has been established by the Deed of Settlement as described in paragraph 20 above; or
(g) to any other tax consequences relating to any facts or proposed transactions referred to herein, other than as specifically described in the rulings given above.
Yours truly,
XXXXXXXXXX
Section Manager
for Division Director
International & Trusts Division
Income Tax Rulings Directorate
Policy and Legislation Branch
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