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: Supplemental Ruling Request to 2007-023388 dated XXXXXXXXXX , 2007. Minor amendments to wording of several paragraphs.
Position: No effect on original rulings as issued.
XXXXXXXXXX
2008-027179
XXXXXXXXXX , 2008
Dear XXXXXXXXXX :
Re: Advance Income Tax Ruling
XXXXXXXXXX
This is in reply to your letter of XXXXXXXXXX wherein you requested amendments to the advance income tax ruling number 2007-023388 dated XXXXXXXXXX , 2007 as amended by documents 2007-025635 dated XXXXXXXXXX , 2007 and 2008-026903 dated XXXXXXXXXX , 2008 (the "Ruling"). As a result, the third sentence of paragraph 26 of the Ruling is amended to read as follows:
The articles of amendment for each of the Sibling Cos will also set out that, if any one of Sibling 1 Co, Sibling 2 Co and Sibling 3 Co, as the case may be, at any time acquires any of its Special A Shares by way of a purchase, redemption or cancellation, such corporation will pay an amount equal to the product obtained when the number of shares to be purchased, redeemed or cancelled is multiplied by the quotient obtained when the lesser of
1) the aggregate Special A Shares Redemption Amount of the Special A Shares issued at that time, and
2) the net realizable value of the assets less liabilities of the corporation immediately before such acquisition,
is divided by the number of Special A Shares issued at that time.
The first sentence of the fifth paragraph of Paragraph 26 will be amended to read as follows:
The articles of amendment for each of the Sibling Cos will also set out that, if any one of Sibling 1 Co, Sibling 2 Co, and Sibling 3 Co, as the case may be, at any time acquires any of its Special C Shares by way of a purchase, redemption or cancellation, such corporation will pay an amount equal to the product obtained when the number of Special C Shares to be purchased, redeemed or cancelled is multiplied by the quotient obtained when the lesser of
1) the aggregate Special C Shares Redemption Amount of the Special C Shares issued at that time, and
2) the net realizable value of the assets less the sum of the liabilities of the corporation immediately before such acquisition and the aggregate Special A Shares Redemption Amount of the Special A Shares issued at that time
is divided by the number of Special C Shares issued at that time.
The first sentence of the second paragraph of Paragraph 28 will be deleted and replaced with the following:
The articles of amendment of TGII will also set out that, if TGII acquires any of its Special C Shares by way of purchase, redemption or cancellation, it will pay an amount equal to the product obtained when the number of Special C Shares to be purchased, redeemed or cancelled is multiplied by the quotient obtained when the lesser of
1) the aggregate Special C Shares Redemption Amount of the Special C Shares issued at that time, and
2) the net realizable value of the assets less the liabilities of the corporation immediately before such acquisition
is divided by the number of Special C Shares issued at that time.
We hereby confirm that, subject to the conditions, limitations, qualifications and comments set out in the Ruling, amended as described above, the rulings given therein will continue to be binding on the Canada Revenue Agency.
Yours truly,
XXXXXXXXXX
Manager
Corporate Reorganizations Section II
Reorganizations and Resources Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch
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© Her Majesty the Queen in Right of Canada, 2008
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