30 November 1995 Ruling 9640273 - DPS - CHANGE IN FACTS

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.

RULINGS DIRECTORATE

CORRESPONDENCE SUMMARY

Principal Issues:

Distress Preferred Share

Position TAKEN:

Requested minor wording change.

Reasons FOR POSITION TAKEN:

Ruling analyzed and approved in context of File 961598.

XXXXXXXXXX 964027

Attention: XXXXXXXXXX

XXXXXXXXXX, 1996

Dear Sirs:

Re: Supplementary Advance Income Tax Ruling
Request - 962809
XXXXXXXXXX

This is further to your telephone conversation of XXXXXXXXXX in regards to the above mentioned advance income tax ruling issued XXXXXXXXXX, 1996 (the "Ruling"). A few minor oversights were noted and brought to our attention. We have accordingly made the following changes as requested:

(1)"Subco C" is substituted for "XXXXXXXXXX" in Paragraph 23 of the Ruling.

(2)The part of paragraph 27(a) that reads "the payment of dividends other than dividends paid on any DPS or dividends paid by any of XXXXXXXXXX directly or indirectly owned subsidiaries and dividends paid, on the death of XXXXXXXXXX, to his estate for the benefit of XXXXXXXXXX..."

is replaced with the following,

"the payment of dividends other than dividends paid on any DPS or dividends paid to XXXXXXXXXX from any of its directly or indirectly owned subsidiaries and dividends paid, on the death of XXXXXXXXXX, to his estate for the benefit of XXXXXXXXXX..."

We confirm that the above changes will not otherwise affect the rulings given in the Ruling and they will continue to be binding on the Department as indicated therein.

Yours truly,

for Director
Financial Industries Division
Income Tax Rulings and
Interpretations Directorate