2096 9614641 - XXXXXXXXXX

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:

Extension of previous ruling on XXXXXXXXXX added to 3-961196; rulings reissued under new number.

Position:

Reasons:

XXXXXXXXXX							3-961464

Attention: XXXXXXXXXX

XXXXXXXXXX, 1996

Dear Sirs:

Re: Advance Income Tax Ruling

This letter is in reply to your request for certain amendments to ruling 3-961196 dated XXXXXXXXXX, 1996. As a result, this letter cancels and replaces ruling 3-961196.

We understand that to the best of your knowledge and that of the taxpayers involved:

none of the issues involved in the requested rulings is being considered by a district office or a taxation centre in connection with a tax return already filed,
and

none of the issues involved in the requested rulings is under objection or appeal.

Unless otherwise stated, every reference herein to a part, section, subsection, paragraph or subparagraph is a reference to the relevant provision of the Income Tax Act (Canada), R.S.C. 1985 (5th Supp.), c.1, as amended (the "Act").

Facts

XXXXXXXXXX a corporation governed by the Canada Business Corporations Act, is a taxable Canadian corporation and a public corporation. The terms "taxable Canadian corporation" and "public corporation", as used herein, have the meanings assigned by subsection 89(1).

The principal business of

XXXXXXXXXX

The issued and outstanding share capital of XXXXXXXXXX consists of

XXXXXXXXXX

Approximately XXXXXXXXXX are held directly by
XXXXXXXXXX

The remaining Common Shares are held by the public.

XXXXXXXXXX has paid regular quarterly dividends of $XXXXXXXXXX per share and
XXXXXXXXXX

Over the period XXXXXXXXXX the dividends paid per share were, on average, XXXXXXXXXX% of the earnings per share. Based on XXXXXXXXXX forecast, a reduction in the regular dividend is not anticipated at this time.

XXXXXXXXXX

The proposed transactions described below are subject to approval by the board of directors of

XXXXXXXXXX

Additional Information

XXXXXXXXXX files it federal income tax return with the XXXXXXXXXX Taxation Centre and deals with the XXXXXXXXXX Taxation Services Office. Its federal tax account number is XXXXXXXXXX.

Proposed Transaction

XXXXXXXXXX

XXXXXXXXXX

Purpose of the Proposed Transactions

XXXXXXXXXX

Ruling Given

Provided that the preceding statements constitute a complete and accurate disclosure of all the relevant facts and proposed transactions and the purposes of the proposed transactions, we confirm that section 183.1 will not apply

XXXXXXXXXX

The above ruling is based on the Act in its present form and does not take into account any proposed amendments to the Act.

This ruling is given subject to the general limitations and qualifications set out in Information Circular 70-6R2 dated September 28, 1990 and is binding on Revenue Canada provided that XXXXXXXXXX proceed without undue delay and are completed within the periods described in the notices
XXXXXXXXXX

Comments

Nothing in this letter should be construed as our confirmation of the tax consequences of any transaction except those consequences expressly confirmed above.

Subsection 84(6) will not apply to any purchase by XXXXXXXXXX of its XXXXXXXXXX as described in paragraph 10 above.

Yours truly,

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