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Technical Interpretation - External summary
30 October 2014 External T.I. 2013-0488881E5 - Upstream Loan -- summary under Subsection 90(9)
On 20 June 2013 FA2 made the $1,500 "FA2 Loan" to Canco for 10 years – but FA2 was wound-up into FA1 on 20 February 2014. ...
Ruling summary
2014 Ruling 2014-0530961R3 - Cross-Border Butterfly -- summary under Distribution
In order that the butterfly transactions could qualify as a tax-free spin-off for Code purposes, TC (a ULC) and Foreign Spinco (an LLC) initially were fiscally transparent for Code purposes – then TC elected to be fiscally regarded in order that it could qualify for Treaty benefits and the Foreign Spinco became a C-corp in order that its spin-off could comply with Code rules. ...
Technical Interpretation - External summary
3 December 2015 External T.I. 2015-0593941E5 F - Allocation of the safe income on hand -- summary under Paragraph 55(2.1)(c)
. … With a dividend in the order of magnitude of $35,000…we could conclude that the reduction is significant or the increase in cost is significant. ...
Ruling summary
2016 Ruling 2015-0616291R3 - Cross-Border Butterfly -- summary under Distribution
Canadian DC holds 3 of the quotas in the capital of Forco 3 and the balance are held by Forco 1 – and otherwise does not hold any shares or units. ...