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July 5, 1995 Welcome to the Income Tax Rulings & Interpretations Directorate Bulletin Board. ... You can scroll through the board or go directly to a topic by sub-searching on a keyword (eg DOCP) in the following index: DOCA 95/7/3 Indians- RRSP'S & Investment Income DOCB 95/7/3 Tax Convention- Resident of a Contracting State DOCC 95/6/30 Incestuous share purchases DOCD 95/6/28 Payments to foster homes DOCE 95/6/28 Medical expenses Directorate Information DOCM Mandate DOCN Mailing Address & General Phone Numbers DOCP Work Section Phone Numbers DOCA Indians- RRSP's & Investment Income Principal Issues: Taxation of status Indians with respect to RRSP withdrawals and investment income. ... Bouffard) LEASING & FINANCING SECTION BUSINESS & PROPERTY INCOME AND EXEMPT ORGANIZATIONS SECTION Wayne Douglas, Chief 957-8957 Roberta Albert, A/Chief 957-2100 Fiona Francis 957-8971 Murray Brake 957-2133 Peter Dunn 957-2747 John Brooks 957-2103 Steve Tevlin 957-2746 Bill Guglich 957-2102 Claude Tremblay 957-2744 Carole Chouinard 957-2098 Mary Pat Baldwin 957-2745 Bill Kerr 957-2139 Les Barrows 952-1361 Milled Azzi 957-8972 DEFERRED INCOME PLANS SECTION PERSONAL & GENERAL SECTION Vacant 957-8979 Paul Fuoco, Chief 957-2141 Wayne Harding 957-9769 Danielle Zion 957-2140 David Duff 957-8968 Marv Eisner 957-2138 Patricia Spice 952-8984 Annemarie Humenuk 957-2134 Mickey Sarazin 957-3499 Jack Szeszycki 957-2135 F. ...

For a corporation to be in financial difficulty we also consider the following factors: a) The corporation must not have current resources such as cash and unused loan capacity (lines of credit or demand loan facilities) available. b) The corporation must not have other sources of funds available. ... Essentially we are ensuring there are no financial resources within the corporate group which could be utilized to alleviate the financial difficulty. ... Appendix B TYPICAL RULINGS Provided that the foregoing statements constitute complete and accurate disclosure of all of the relevant facts and proposed transactions, we confirm the following: A. the Preferred Shares of Newco to be issued to the Bank, as described in paragraph () of the Proposed Transactions (the "Shares"), will be shares described in subparagraph (e)(iii) of the definition of "term preferred share" in subsection 248(1) of the Act for a period not exceeding five years from the date of their issuance and, accordingly, the Bank will not be denied a deduction under subsection 112(1) of the Act for dividends received or deemed to have been received on the Shares during such period; B. subsection 112(2.4) of the Act will not, by virtue of subsection 112(2.5) of the Act, apply to deny the Bank a deduction under subsection 112(1) of the Act for dividends received or deemed to have been received on the Shares; C. no amount will be included in computing the income of Newco under paragraph 12(1)(c) or 12(1)(x), or subsection 12(3), 12(9), 16(1) or 246(1) or section 9 of the Act in respect of capital contributions made or required to be made by Distressco to Newco, as described in paragraph () of the Proposed Transactions, nor will such amounts constitute proceeds of disposition, as defined in paragraph 54(h) of the Act, to Newco from the disposition by it of any property; Document Disclosed Pursuant to The Access To Information Act D.Document Divulgué en vertu de la loi sur l'accès à l'information D. subsection 80(1) of the Act will not apply in respect of Distressco by virtue of the fact that interest will not be paid or payable by Distressco to Newco on the Purchased Loans, as described in paragraph () of the Proposed Transactions; E. subject to paragraph 20(1)(e.1) of the Act, expenses incurred by Newco in the course of borrowing money and issuing the Shares, will be deductible pursuant to paragraph 20(1)(e) of the Act to the extent such expenses are reasonable in the circumstances; F. the cost amount, within the meaning of subsection 248(1) of the Act, to the Bank of the Shares will, immediately after the time that the Shares are issued, be equal to the amount paid by the Bank for those Shares as described in paragraph () of the Proposed Transactions; G. the cost amount, within the meaning of subsection 248(1) of the Act, to Newco of the Purchased Loans will, immediately after they are acquired from the Bank, equal the purchase price paid therefor as described in paragraph () of the Proposed Transactions; H. no amount will be included in computing the income of the Bank under subsection 56(2) of the Act in respect of any capital contributions made by Distressco to Newco as described in paragraph () of the Proposed Transactions; I. if the Purchased Loans are reacquired by the Bank, as described in paragraph () of the Proposed Transactions, the cost amount, within the meaning of subsection 248(1) of the Act, to the Bank of the Purchased Loans will be the purchase price paid therefor; and J. as a result of the Proposed Transactions, in and of themselves, subsection 245(2) of the Act will not apply to redetermine the tax consequences confirmed in the rulings given above. ...

PRINCIPAL ISSUES: Changes to the proposed transactions described in the advance income tax ruling 2007-023750 [] to add greater detail to the described transactions, to change a share consolidation ratio, to inform of an apportionment of the distributing corporation's credit facility to Spinco / Amalco and to inform of a normal course issuer bid authorization that will be obtained for Amalco. POSITION: The rulings given in 2007-023750 [] will remain the same subject to limited clean-up changes that are being made. ... Yours truly, XXXXXXXXXX for the Director Reorganizations and Resources Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Other resources, including the pamphlet you submitted entitled "Investment in Czechoslovakia", indicate that the S.R.O. is considered a separate legal entity in those Republics. ... Yours truly, for Director Reorganizations and Foreign Division Rulings Directorate Legislative and Intergovernmental Affairs Branch ANGIND E DOCNUM 9401365 REPLACES TYPEKEY R AUTHORDV LEGS AUTHOR CCHOUI DESCKEY 5 RATEKEY 1 REFDATE 940722 ETADYEAR ETADSORT ADMINACC LEGS ACCESSLV LEGS99 SUBJECT Non-qualifying real property SECTION ITA-110.6(1) SECTION SECTION SECTION SECTION $$$$ 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. ...

" 7. Paragraph 36 will be amended to read as follows: Oco will redeem all of its Oco XXXXXXXXXX Shares held by Cco for an amount equal to their fair market value, being the Oco XXXXXXXXXX Aggregate Redemption Amount. ... Yours truly, for Director Reorganizations and Resources Division Income Tax Rulings Directorate Policy and Legislation Branch ...

The second reason also presumes that the taxpayer has some economic benefit which constitutes a Canadian resource property and which he is relinquishing to the other participants who are making the overpayment in consideration therefor. ... The question and answer was reviewed by John Kurrant, Oil & Gas Specialist on June 12 and he said that he does not have any concerns. ...

Capital Account (See Section 49 of the Act)** Call options Holder (Purchaser) Writer (Vendor) Exercised Premium added to Premium is capital gain cost of shares at time of writing call ** Expires Premium is capital No tax consequences loss in year of expiry Close Out Net gain or loss in Premium is capital loss year of close out in year of close out Put options Holder (Purchaser) Writer (Vendor) Exercised Premium deducted Capital gain at time of from proceeds writing put *** Expires Premium is capital No tax consequences loss Close Out Net gain or loss Premium is capital loss in in year of close out year of close out * Premium refers to the cost of the call or put option. ** Note that subsection 49(5) is not relevant for exchange-traded options. *** Capital gain may be reversed and added to proceeds of securities received in a later year under subsection 49(4). ... A Canadian corporation (Canco) with debt denominated in a foreign currency (currency "X") on which interest is deductible enters into bona fide agreements to * borrow funds denominated in other foreign currency (currency "Y"); * swap those funds for an equivalent amount of funds denominated in currency X with a financial intermediary; * pay to and receive from that intermediary amounts sufficient to meet the periodic interest payments due on one another's respective obligations; * reswap the currencies at the same amount initially swapped on a set redemption date; and * repay the currency Y debt on the redemption date. ... (b) If the borrower repays the loan by delivery out of its own Canadian production, we assume it is the fair market value of the gold at the date of repayment that is to be taken into account in determining the borrower's resource profits under Regulation 1204. ...

Skinner Chief Energy Efficiency Division Technology Branch 5-9241 Energy, Mines and Resources Canada W.P. ... Revenue Canada Contact Wehn taxpayers request the name of a contact at Revenue Canada you may inform them that: • Written inquiries should be forwarded to the Director-General Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch Revenue Canada Taxation 875 Heron Road Ottawa, Ontario K1A 0L8 • For telephone inquiries they may call the Group #23 telephone person (613) 957-2088. ...

Partnership1 was formed in XXXXXXXXXX to XXXXXXXXXX; • a XXXXXXXXXX% limited partnership interest in Partnership2, the FMV of which is estimated at approximately $XXXXXXXXXX as at XXXXXXXXXX. ... The federal business number of the parties referred to herein, the location of the tax services office and taxation centre where their returns are filed, and the address of their head office are as follows: XXXXXXXXXX • Business Number: XXXXXXXXXX • Tax Services Office: XXXXXXXXXX • Taxation Centre: XXXXXXXXXX • Address: XXXXXXXXXX XXXXXXXXXX • Business Number: XXXXXXXXXX • Tax Services Office: XXXXXXXXXX • Taxation Centre: XXXXXXXXXX • Address: XXXXXXXXXX PURPOSES OF THE PROPOSED TRANSACTIONS 45. ... Yours truly, XXXXXXXXXX for Director Reorganizations and Resources Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Samson Bélair / Deloitte & Touche REVENUE CANADA CAROLE GOUIN-TOUSSAINT, C.G.A., REPRESENTATIVES: Head of Working Group on Internal Communications Revenue Canada- Taxation ANDRE THIBAULT, C.G.A. ... ANSWER 22 INTEREST PAYABLE TO A NON-RESIDENT The Department's concern with respect to sinking funds is with situations where liquid assets are invested in a fund in a systematic manner in order to give the lender access to financial resources sufficient to reimburse the capital lent. ... If the asset is sold by A Inc. to its subsidiary (B Inc.) without resource to the rollover provisions, subparagraph 69(1)(b)(i) of the Act will apply, and the proceeds of disposition for A Inc. will be deemed to be $1,000, that is, the fair market value of the asset transferred. ...