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: Standard Loss Consolidation. Shift of current year losses to affiliated corporation through interest expense on inter-corporate debt.
Position: Favourable Ruling Issued
Reasons: Legislative and administrative requirements met. Prior ruling issued to same taxpayer with respect to similar transactions.
XXXXXXXXXX 2009-032486
XXXXXXXXXX , 2009
Dear XXXXXXXXXX :
Re: XXXXXXXXXX
(collectively, the "Taxpayers")
Advance Income Tax Ruling Request
This is further to your letter requesting an advance income tax ruling for the above-noted Taxpayers dated XXXXXXXXXX and to various subsequent telephone conversations and electronic correspondence (XXXXXXXXXX ).
You have advised us that to the best of your knowledge and that of the Taxpayers, none of the issues involved in this ruling request are:
(i) in an earlier return of the Taxpayers or persons related to the Taxpayers;
(ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the Taxpayers or persons related to the Taxpayers;
(iii) under objection by the Taxpayers or persons related to the Taxpayers;
(iv) before the courts; or
(v) the subject of a ruling previously issued by the Income Tax Rulings Directorate.
Unless otherwise noted, all statutory references herein are to the Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.), as amended (hereinafter referred to as the "Act"). Unless otherwise noted, all references to currency are to Canadian dollars.
Defined Terms
In this letter, unless otherwise specified, all monetary amounts are expressed in Canadian dollars and the following terms have the meanings specified:
(a) "affiliated persons" has the meaning assigned by subsection 251.1(1);
(b) "allowable capital loss" has the meaning assigned by section 38;
(c) "BCA" means the Business Corporations Act, R.S.O. 1990 c. B-16, as amended;
(d) "Canadian-controlled private corporation" or "CCPC" has the meaning assigned by subsection 125(7);
(e) capital property" has the meaning assigned by section 54;
(f) "cost amount" has the meaning assigned by subsection 248(1);
(g) "CRA" means the Canada Revenue Agency;
(h) "Daylight Loan" has the meaning assigned in Paragraph 20;
(i) "dividend rental arrangement" has the meaning assigned by subsection 248(1);
(j) "financial intermediary corporation" has the meaning assigned by subsection 191(1);
(k) "fiscal period" has the meaning assigned by section 249.1;
(l) "GPCo 1" means XXXXXXXXXX .;
(m) "GPCo 2" means XXXXXXXXXX .;
(n) "guarantee agreement" has the meaning assigned by subsection 112(2.2);
(o) "LossCo" means XXXXXXXXXX ;
(p) "LossCo Demand Note" has the meaning assigned in Paragraph 23;
(q) "LossCo Sub" means XXXXXXXXXX .;
(r) "LossCo Sub Demand Note" has the meaning assigned in Paragraph 32;
(s) "LossCo Sub Preferred Shares" has the meaning assigned in Paragraph 18;
(t) "LP1" means XXXXXXXXXX ;
(u) "LP2" means XXXXXXXXXX ;
(v) "MVS" has the meaning assigned in Paragraph 8;
(w) "NewCo" means a newly-incorporated corporation described in Paragraph 19;
(x) "NewCo II" means a newly-incorporated corporation that may be incorporated in circumstances described in Paragraph 27;
(y) "NewCo Class I Common Shares" has the meaning assigned in Paragraph 19;
(z) "NewCo Class II Common Shares" has the meaning assigned in Paragraph 19;
(aa) "NewCo Demand Note" has the meaning assigned in Paragraph 21;
(bb) "non-capital loss" has the meaning assigned by subsection 111(8);
(cc) "OpCo" means XXXXXXXXXX .;
(dd) "paid-up capital" has the meaning assigned by subsection 89(1);
(ee) "Paragraph" means a numbered paragraph in this letter;
(ff) "ParentCo" means XXXXXXXXXX .;
(gg) "permanent establishment" has the meaning assigned by Part IV of the Income Tax Regulations;
(hh) "Portfolio" has the meaning assigned in Paragraph 10;
(ii) "Proposed Transactions" means the proposed transactions described in Paragraphs 19 to 37
(jj) "public corporation" has the meaning assigned by subsection 89(1);
(kk) "related persons" has the meaning assigned by section 251;
(ll) "safe-income determination time" has the meaning assigned by subsection 55(1);
(mm) "specified financial institution" has the meaning assigned by subsection 248(1);
(nn) "SVS" has the meaning assigned in Paragraph 8;
(oo) "taxable Canadian corporation" has the meaning assigned by subsection 89(1);
(pp) "taxable capital gain" has the meaning assigned by section 38;
(qq) "taxable dividend" has the meaning assigned by subsection 89(1);
(rr) "taxable income" has the meaning assigned by subsection 248(1); and
(ss) "X" means XXXXXXXXXX .
Facts
1. X is an individual who is a resident of Canada for the purposes of the Act.
2. ParentCo is a taxable Canadian corporation and a CCPC. ParentCo was incorporated under the BCA. X controls ParentCo and is its sole shareholder.
3. GPCo1 is a taxable Canadian corporation and a CCPC. GPCo1 was incorporated under the BCA. X controls GPCo1 and is its sole shareholder.
4. GPCo2 is a taxable Canadian corporation and a CCPC. GPCo1 was incorporated under the BCA. X controls GPCo2 and is its sole shareholder.
5. OpCo is a taxable Canadian corporation and a public corporation whose common shares are listed for trading on the XXXXXXXXXX Stock Exchange under the symbol "XXXXXXXXXX ". The authorized and issued share capital of OpCo consists of approximately XXXXXXXXXX common shares. As at XXXXXXXXXX , OpCo had a market capitalization of approximately $XXXXXXXXXX . As at XXXXXXXXXX , OpCo had consolidated revenues of approximately $XXXXXXXXXX .
6. OpCo is a XXXXXXXXXX . OpCo's most recent taxation year ended on XXXXXXXXXX . OpCo has permanent establishments in all XXXXXXXXXX provinces and XXXXXXXXXX in Canada.
Provincial Allocation
XXXXXXXXXX XXXXXXXXXX
7. LossCo is a taxable Canadian corporation and a public corporation. LossCo's taxation year-end is XXXXXXXXXX . LossCo has permanent establishments in XXXXXXXXXX
Provincial Allocation
XXXXXXXXXX XXXXXXXXXX
8. The authorized and issued share capital of LossCo consists of a class of XXXXXXXXXX , a class of XXXXXXXXXX and a class of XXXXXXXXXX.
9. As at XXXXXXXXXX , LossCo had a market capitalization of approximately $XXXXXXXXXX . LossCo had consolidated revenues of approximately $XXXXXXXXXX in its XXXXXXXXXX fiscal period. LossCo principally XXXXXXXXXX .
10. LossCo Sub is a taxable Canadian corporation. LossCo owns (directly and indirectly) all of the issued and outstanding shares of LossCo Sub. LossCo Sub's fiscal and taxation year-end is XXXXXXXXXX . LossCo Sub owns investments in XXXXXXXXXX . Lossco Sub also owns a portfolio of XXXXXXXXXX (the "Portfolio").
11. GPCo 1 is the general partner of LP1, a limited partnership. ParentCo is a limited partner of LP1. The other limited partners of LP1 are taxable Canadian corporations controlled by ParentCo.
12. GPCo 2 is the general partner of LP2, a limited partnership. LP1 is the sole limited partner of LP2.
13. LP1, LP2, ParentCo and a number of taxable Canadian corporations controlled by ParentCo together hold approximately XXXXXXXXXX common shares of OpCo, representing approximately XXXXXXXXXX % of the issued and outstanding common shares of OpCo. LP1 and LP2 directly hold a total of approximately XXXXXXXXXX % of the common shares of OpCo.
14. X holds all the shares of and controls each of GPCo 1, GPCo 2 and ParentCo. X controls OpCo because GPCo 1 and GPCo 2 have the exclusive authority to manage the operation and affairs of LP1 and LP2, respectively.
15. X controls a number of taxable Canadian corporations that collectively hold approximately XXXXXXXXXX % of the issued and outstanding SVS. X also controls a taxable Canadian corporation that holds all the issued and outstanding MVS. X therefore controls LossCo.
16. As at XXXXXXXXXX , the balance of LossCo's non-capital losses as filed (estimated for XXXXXXXXXX ) was approximately $XXXXXXXXXX . The non-capital losses were incurred and expire as follows:
Approximate Amount of Loss
Year Incurred
Year of Expiry
$XXXXXXXXXX
XXXXXXXXXX
XXXXXXXXXX
$XXXXXXXXXX
XXXXXXXXXX
XXXXXXXXXX
$XXXXXXXXXX
XXXXXXXXXX
XXXXXXXXXX
$XXXXXXXXXX
XXXXXXXXXX
XXXXXXXXXX
$XXXXXXXXXX
XXXXXXXXXX
XXXXXXXXXX
17. OpCo and LossCo are affiliated persons since they are both controlled by X.
18. The authorized capital of LossCo Sub includes XXXXXXXXXX preferred shares of LossCo Sub (the "LossCo Sub Preferred Shares"). The LossCo Sub Preferred Shares are non-voting, redeemable, subject to applicable law, at any time at the option of LossCo Sub for an amount equal to the amount for which they were issued plus any accrued and unpaid dividends, and carry a cumulative dividend entitlement at a rate equal to XXXXXXXXXX % per year. LossCo holds LossCo Sub Preferred Shares which it received as consideration for the previous transfer of the Portfolio to LossCo Sub.
Proposed Transactions
19. LossCo will incorporate NewCo under the BCA. The authorized share capital of NewCo will consist of an unlimited number of two classes of common shares (the "NewCo Class I Common Shares" and the "NewCo Class II Common Shares"). NewCo will be a taxable Canadian corporation. NewCo will not carry on any business and its activities will be limited to investing in LossCo Sub Preferred Shares as described in Paragraph 22. NewCo will issue XXXXXXXXXX common shares of NewCo to LossCo for $XXXXXXXXXX upon incorporation. NewCo will have a fiscal year-end date of XXXXXXXXXX .
20. LossCo will borrow $XXXXXXXXXX from a financial institution on a daylight loan basis (the "Daylight Loan") on arm's length commercial terms customary for this type of loan.
21. LossCo will use the entire amount of the proceeds from the Daylight Loan to make an interest bearing loan to Newco. Such loan will be evidenced by an interest bearing demand note issued by Newco to LossCo (the "Newco Demand Note").
22. NewCo will use the entire amount of the proceeds borrowed from LossCo to subscribe for LossCo Sub Preferred Shares. The LossCo Sub Preferred Shares will have a redemption amount and paid-up capital equal to the amount of the subscription.
23. LossCo Sub will use the entire amount of the proceeds received from Newco on the subscription for LossCo Sub Preferred Shares to make a non-interest bearing loan to LossCo. Such loan will be evidenced by a non-interest bearing demand note issued by LossCo to LossCo Sub (the "LossCo Demand Note").
24. LossCo will use the entire amount of the proceeds borrowed from LossCo Sub to repay the Daylight Loan to the financial institution.
25. The management of LossCo and NewCo believe that LossCo could reasonably be expected to borrow $XXXXXXXXXX to finance additional investments based on LossCo's current net asset value and its existing sources of cash flow.
26. The NewCo Demand Note will bear interest at a rate that will be reasonable based on the circumstances, which rate will not be in excess of the rate that would be required by a third party lender. The management of Lossco and NewCo has concluded that the interest rate to be charged on the NewCo Demand Note will not exceed XXXXXXXXXX %.
27. It is expected that cash from LossCo Sub's own operations will be sufficient to satisfy any dividend payments on the LossCo Sub Preferred Shares. In the event of a shortfall, LossCo will incorporate NewCo II and subscribe for shares of NewCo II in consideration for a cash contribution equal to the amount of the shortfall required by LossCo Sub to fund dividend payments on the LossCo Sub Preferred Shares. NewCo II will be a taxable Canadian corporation. With the proceeds from the issuance of shares to LossCo, NewCo II will make a cash capital contribution to LossCo Sub in the amount of the shortfall to fund the payment of dividends on the LossCo Sub Preferred Shares. No shares will be issued by LossCo Sub with respect to the contribution of capital and no amount will be added to the stated capital account maintained in respect of any class of shares of LossCo Sub or, for greater certainty, to the paid-up capital of any class of shares of LossCo Sub. The amount of this contribution of capital, if any, will be recorded as contributed surplus for accounting purposes. The contribution of capital, if any, will not be income of LossCo Sub pursuant to generally accepted accounting principles and will not increase the fair market value of any shares of LossCo Sub other than the LossCo Sub Preferred Shares held by NewCo.
28. The transactions described in Paragraphs 29 to 37 will occur in the following order on or before XXXXXXXXXX (i.e., the last day of the XXXXXXXXXX taxation year of OpCo).
29. LossCo Sub will pay the balance of any accrued and unpaid dividends on the LossCo Sub Preferred Shares. It is expected LossCo Sub will have sufficient funds from its own operations to pay the amount of such dividends. In the event that LossCo Sub requires additional funds to fully pay the amount of such dividends, LossCo Sub will receive a capital contribution from NewCo II in the manner described in Paragraph 27 to the extent of the shortfall so that the capital contribution, along with the cash from LossCo Sub's own operations, will be sufficient to satisfy the dividend payments on the LossCo Sub Preferred Shares.
30. NewCo will pay the balance of any accrued and unpaid interest on the NewCo Demand Note.
31. LossCo Sub will demand repayment of the LossCo Demand Note. LossCo will repay the LossCo Demand Note by assigning the Newco Demand Note to LossCo Sub in full satisfaction of all amounts due under the LossCo Demand Note.
32. LossCo Sub will redeem its preferred shares held by Newco in exchange for an interest bearing demand note issued by LossCo Sub (the "LossCo Sub Demand Note"). The LossCo Sub Demand Note will bear interest at a rate that will be reasonable based on the circumstances, which rate will not be in excess of the rate that would be required by a third party lender.
33. LossCo Sub and Newco will agree to set off the amount due under the Newco Demand Note against the amount due under the LossCo Sub Demand Note.
34. OpCo will subscribe for XXXXXXXXXX NewCo Class II Common Shares in consideration for a cash contribution equal to the fair market value of the XXXXXXXXXX NewCo Class I Common shares held by LossCo. The determination of the fair market of the NewCo Class I Common Shares and the subscription price for the NewCo Class II Common Shares will be a matter of negotiation between LossCo and OpCo.
35. NewCo will use the proceeds from the share subscription in Paragraph 34 to purchase for cancellation the NewCo Class I Common Shares held by LossCo.
36. NewCo will commence winding-up into OpCo in accordance with the provisions of the BCA.
37. In the event that NewCo II has been incorporated and has made any capital contribution to LossCo Sub described in Paragraph 27 or 29, NewCo II will be wound-up into LossCo within sixty days of the completion of the Proposed Transactions described in the forgoing Paragraphs.
38. In computing LossCo's taxable income for the taxation years ending XXXXXXXXXX , LossCo will not deduct any amount in respect of its non-capital loss for the taxation years that ended on XXXXXXXXXX , respectively.
39. None of the LossCo Sub Preferred Shares, the NewCo Class I Common Shares and the NewCo Class II Common Shares will be, at any time during the implementation of the Proposed Transactions described herein:
(a) the subject of any undertaking that is a guarantee agreement;
(b) the subject of a dividend rental arrangement;
(c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or
(d) issued for consideration that it is or includes:
(i) an obligation of the type described in subparagraph 112(2.4)(b)(i) other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251 (5)(b)); or
(ii) any right of the type described in subparagraph 112(2.4)(b)(ii).
40. LossCo and LossCo Sub are specified financial institutions and NewCo will be a specified financial institution. LossCo and LossCo Sub are not, and NewCo will not be, financial intermediary corporations.
41. LossCo, NewCo, LossCo Sub, ParentCo, GPCo 1, GPCo 2 and OpCo are affiliated persons and related persons and will continue to be affiliated and related to each other throughout the Proposed Transactions.
Purpose of the Proposed Transactions
42. The purpose of the Proposed Transactions is to consolidate profits and losses within a group of taxable Canadian corporations that are affiliated persons by enabling LossCo to earn sufficient interest income to utilize a portion of its expected XXXXXXXXXX losses and to enable NewCo to obtain an interest expense deduction to generate a non-capital loss in its XXXXXXXXXX taxation year. The non-capital loss is expected to be used to reduce OpCo's taxable income in its fiscal XXXXXXXXXX or fiscal XXXXXXXXXX taxation year.
RULINGS
Provided that the preceding statements constitute a complete and accurate disclosure of all of the relevant facts, additional information, proposed transactions and the purposes of the Proposed Transactions, and provided further that the Proposed Transactions are completed in the manner described above, we rule as follows:
A. Subsection 55(2) will apply to a taxable dividend that Newco receives from LossCo Sub on the LossCo Sub Preferred Shares as described in Paragraph 29, unless none of the purposes of the dividend was to effect a significant reduction in the portion of the capital gain that, but for the dividend, would have been realized on a disposition at fair market value of the LossCo Sub Preferred Shares immediately before the dividend and that could be reasonably be considered to be attributable to anything other than income earned or realized by any corporation after 1971 and before the relevant safe-income determination time.
B. Subsection 55(2) will apply to the taxable dividend that Lossco is otherwise deemed to receive pursuant to subsection 84(3) as a consequence of the purchase for cancellation of the Newco Class I Common Shares described in Paragraph 35, unless the amount of the reduction to the accrued capital gain on the Newco Common Shares as a consequence of such dividend is wholly attributable to income earned or realized by Newco, determined as of the relevant safe-income determination time.
C. Without considering the winding-up of Newco into Opco as described in Paragraph 36, the Proposed Transactions described herein, in and by themselves, will not be considered to result in any disposition or increase in interest described in any of subparagraphs 55(3)(a)(i) to (v).
D. Without considering the application of subsection 55(2), dividends received by Newco on the Lossco Sub Preferred Shares will be taxable dividends that will be deductible pursuant to subsection 112(1) in computing the taxable income of Newco for the taxation year in which the dividends are received, and for greater certainty, such deduction will not be precluded by any of subsections 112(2.1), 112(2.2), 112(2.3) or 112(2.4).
E. Newco will not be subject to tax under Part IV.1 in respect of any dividends received from Lossco Sub on the Lossco Sub Preferred Shares by virtue of paragraph (b) of the definition of "excepted dividend" in section 187.1.
F. Newco will not be subject to Part IV tax in respect of any dividends received from LossCo Sub on the LossCo Sub Preferred Shares, except to the extent that paragraph 186(1)(b) applies to impose such tax.
G. LossCo Sub will not be subject to tax under Part VI.1 in respect of any dividends paid to Newco on the LossCo Sub Preferred Shares by virtue of paragraph (a) of the definition of "excluded dividend" in subsection 191(1).
H. Provided that Newco has a legal obligation to pay interest on the Newco Demand Note, and Newco continues to hold the LossCo Sub Preferred Shares it acquires, in the manner described in Paragraph 22, for the purpose of gaining or producing income from property, Newco will be entitled, pursuant to paragraph 20(1)(c), to deduct the lesser of (i) the interest paid or payable (depending on the method regularly followed by Newco in computing its income for purposes of the Act) in respect of the year on the Newco Demand Notes or (ii) a reasonable amount in respect thereof.
I. On the purchase for cancellation of the XXXXXXXXXX Newco Class I Common Shares described in Paragraph 35, Newco will be deemed to have paid, and Lossco will be deemed to have received, pursuant to subsection 84(3), a dividend equal to the amount by which the amount paid by Newco on the purchase exceeds the paid-up capital of the Newco Class I Common Shares immediately before the purchase, and, without considering the application of subsection 55(2), the amount of such dividend:
(i) will be included in Lossco's income pursuant to section 82 and paragraph 12(1)(j); and
(ii) will be a taxable dividend that will be deductible pursuant to subsection 112(1) in computing the taxable income of Lossco for the taxation year in which the dividend is received, and for greater certainty, such deduction will not be precluded by any of subsections 112(2.1), 112(2.2), 112(2.3) or 112(2.4).
J. Pursuant to paragraph 256(7)(a), control of Newco will be deemed not to have been acquired, for the purposes of the provisions enumerated in subsection 256(7), solely because of the Proposed Transactions described in Paragraphs 34 and 35.
K. The settlement of the LossCo Demand Note, the Newco Demand Note and the LossCo Sub Demand Note will not give rise to a "forgiven amount" within the meaning of subsections 80(1) and 80.1(1).
L. After the winding-up of Newco into Opco described in Paragraph 36 is completed, the provisions of subsection 88(1.1) of the Act will apply to permit Opco to deduct the non-capital losses of Newco in computing its taxable income for any taxation year of Opco to commence after the commencement of the winding-up, to the extent that the requirements in paragraphs 88(1.1)(a) and (b) are satisfied and subject to the limitations in paragraph 88(1.1)(e) and section 111.
M. Subsections 15(1), 56(2), and 246(1) will not apply to the Proposed Transactions, in and by themselves.
N. Subsection 245(2) will not apply as a result of the Proposed Transactions, in and by themselves, to redetermine the consequences confirmed in the rulings given above.
O. The general anti-avoidance provision of a province with which the Government of Canada has entered into a Tax Collection Agreement will not be applied, as a result of the proposed transactions, in and by themselves, to redetermine the tax consequences confirmed in the rulings given above, in respect of a taxation year in respect of which such Tax Collection Agreement is in effect.
These rulings are given subject to the limitations and qualifications set forth in Information Circular 70-6R5 issued on May 17, 2002, and are binding on the CRA provided that the Proposed Transactions described in Paragraphs 19 to 36 are completed on or before XXXXXXXXXX , and, in the event Newco II is incorporated, the Proposed Transaction described in Paragraph 37 is completed on or before XXXXXXXXXX .
The above rulings are based on the Act in its present form and do not take into account any proposed amendments to the Act, which if enacted, could have an effect on the rulings provided herein.
A. It is our view that the winding-up of Newco into Opco as described in Paragraph 36 or the winding-up of Newco II into Lossco contemplated in Paragraph 37 could cause subsection 55(2) of the Act to apply to the taxable dividends referred to in Rulings A and B. However, we understand that the Department of Finance has issued a letter dated April 21, 2005 (the "comfort letter"), indicating that it was prepared to recommend to the Minister of Finance that situations described in the comfort letter (i.e. essentially where a wholly-owned subsidiary is amalgamated with, or wound-up into, its parent) should not result in a significant increase in the interest of the subsidiary solely as a result of the application of paragraphs 55(3.01)(b) and (c). If such legislation is ever enacted and is effective for the period in which these Proposed Transactions take place, it is possible that subsection 55(2) may not apply to the dividends described in Rulings A and B.
B. Based on the representation provided in Paragraph 38, LossCo will not deduct any amount in respect of its non-capital losses described in Paragraph 16 for its taxation years that will end on XXXXXXXXXX and XXXXXXXXXX . It is our view that if the non-capital losses for Lossco are so deducted in computing its income, that there could be an inappropriate "refreshing" as a consequence of the Proposed Transactions, with the result that subsection 245(2) could apply to redetermine the consequences confirmed in Rulings H and L above.
C. Subject to Ruling O, nothing in this letter should be construed as implying that the CRA has agreed to or reviewed:
(a) the determination of the adjusted cost base, paid-up capital or fair market value of any shares or other property referred to herein;
(b) the GST implications of any of the Proposed Transactions;
(c) the amount of any non-capital loss or any other amount of any corporation referred to herein;
(d) the application or non-application of the general anti-avoidance provisions of any province; and
(e) any other tax consequence relating to the facts, Proposed Transactions or any transaction or event taking place either prior to the Proposed Transactions or subsequent to the Proposed Transactions, whether described in this letter or not, other than those specifically described in the rulings given above, including whether any of the Proposed Transactions would also be included in a series of transactions or events that include other transactions or events that are not described in this letter.
Yours truly,
for Division Director
Reorganizations and Resources Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch
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