2007 Ruling 2007-0254581R3 - Supplemental Ruling

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.

Principal Issues: Change in facts

Position: Accepted

Reasons: No impact on the Ruling (document #2007-024174) issued

XXXXXXXXXX 								2007-025458

XXXXXXXXXX , 2007

Dear XXXXXXXXXX:

Re: XXXXXXXXXX
XXXXXXXXXX
XXXXXXXXXX
XXXXXXXXXX
Supplemental Advance Income Tax Ruling Request

This is in reply to your emails ("Emails") of XXXXXXXXXX, and is supplemental to our advance income tax ruling number 2007-024174 that was issued to the above-captioned taxpayers on XXXXXXXXXX, 2007 (the "Ruling"). Unless otherwise defined, all capitalized terms in this letter have the meanings assigned to them in the Ruling.

In your Emails, you have requested that the aggregate redemption amounts and FMV of the DC1 Preferred Shares that DC1 would issue to each of TC1, TC2 and TC3 as described in Paragraph 12(a) be amended as follows:

(a) DC1 Preferred Shares having an aggregate redemption amounts and FMV equal to the sum of $XXXXXXXXXX plus one-third of the excess amount which is the amount, if any, by which the amount of DC1's GRIP balance at the end of its XXXXXXXXXX taxation year exceeds the total amount of the eligible dividends that DC1 paid to TC1, TC2 and TC3 as described in Paragraph 1; and

Confirmation

We confirm that Paragraph 12(a) is hereby amended in the manner that you have requested above. Notwithstanding this amendment, we hereby confirm that, subject to the conditions, limitations, qualifications and comments set out in the Ruling, the Ruling will continue to be binding on CRA. For greater certainty, we are not providing any assurance as to whether those dividends that DC1 paid to TC1, TC2 and TC3 as described in Paragraph 1 would be eligible dividends.

Yours truly,

XXXXXXXXXX
Section Manager
for Division Director
Reorganizations and Resources Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch