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Mark Woltersdorf, "Restrictive Covenants – The Final Chapter (For Now) – Part II", CCH Tax Topics, No. 2135, 7 February 2013, p. 1 at pp. 3-4:-- summary under Subsection 56.4(12) Summary Under Tax Topics- Income Tax Act- Section 56.4- Subsection 56.4(12) Discussions with the Department of Finance indicate that the intent of paragraph 56.4(12)(b) is to prevent a taxpayer from arguing that an amount received or receivable by that taxpayer that reasonably relates to an RC granted by another taxpayer should not be included in that taxpayer's income because paragraph 68(c) prevents the Minister from allocating any portion of the RC to them. ...

Joint Committee, "Subject: Proposed Part II.2 Tax – Tax on Repurchases of Equity – ‘Reorganization Transaction", 26 March 2024 Joint Committee Submission-- summary under Paragraph (c) Summary Under Tax Topics- Income Tax Act- Section 183.3- Subsection 183.3(1)- Reorganization- Paragraph (c) Wind-Up of Targetco into Acquisitionco A public company target (“Targetco”), whose shares are not delisted until after a delay, is acquired by “Acquisitionco” and then wound-up into it. ...

Joint Committee, "Subject: Proposed Part II.2 Tax – Tax on Repurchases of Equity – ‘Reorganization Transaction", 26 March 2024 Joint Committee Submission-- summary under Variable B Summary Under Tax Topics- Income Tax Act- Section 183.3- Subsection 183.3(2)- Variable B Acquisition of Targetco for cash and Acquisitionco equity Where the shareholders of Targetco (which will not be delisted until some time thereafter) are to receive a combination of cash and shares of Acquisitionco, the cash component is included in Variable B of the formula in proposed s. 183.3(2) (so that it is subject to the tax) because equity of a covered entity (Targetco) is acquired in the taxation year pursuant to a reorganization transaction described in para. ...

Roderick I’Anson Banks, "Lindley & Banks on Partnership", (Sweet & Maxwell, 20th Ed.) 2017-- summary under Section 6 Summary Under Tax Topics- Other Legislation/Constitution- Ontario- Partnerships Act- Section 6 Effect of s. 5 of the Partnership Act 1890 (U.K.) ...

PWC, "Tax Insights: Investment limited partnerships ─ GST/HST & QST filing obligations", Issue 2020-27, May 04, 2020-- summary under Subsection 225.4(6) Summary Under Tax Topics- Excise Tax Act- Section 225.4- Subsection 225.4(6) Addition of ILPs to SLFI world Most Canadian resident investment limited partnerships (ILPs) will be considered to be a Selected Listed Financial Institution (SLFI), starting January 1, 2019 (i.e. the 2019 fiscal year). ...

[Footnote 65 See, for example, paragraphs 1.22 and 1.38 of … S4-F2-C1 … 2012-0436771E5 … and … 9325325 ….] ... Alternatively, if the intermediary is considered to be in the business of lending money, consideration could be given to whether the penalty paid might be deductible, under section 9 …. [I]t might be possible for the intermediary to avoid the payment and receipt of the prepayment penalty by assigning its debt receivable to the ultimate lender in satisfaction of the intermediary’s debt to the ultimate lender …. ...

Carrie Aiken, Johnson Tai, "Debt Restructuring Transactions – Issues, Strategies and Trends", 2016 CTF Annual Conference draft paper-- summary under Paragraph 80(2)(k) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(2)- Paragraph 80(2)(k) Facts of conversion of DIP financing and USD bonds to equity (pp. 7-8) Canco has US$1 billion of bonds (the " Bonds ") payable to unrelated parties (the " Bondholders ")… [who] do not constitute a "group of persons"…. ... An unrelated Canadian corporation (" Buyer ") proposes to provide US$200 million of debtor-in-possession (" DIP ") financing. … Buyer anticipates that after Canco emerges from CCAA, Buyer will own approximately 67% of the shares of Canco (with a fair market value of US$200 million) as a result of Buyer receiving shares of Canco in complete settlement of the DIP financing, and the Bondholders will receive shares of Canco representing 33% of the issued and outstanding Canco shares (with a fair market value of US$100 million) in complete settlement of the Bonds. ... Making an election for subsection 256(9) not to apply in this "same day" situation would reverse the sequence of events so that the Bond settlement occurs before the DIP financing (and resulting LRE). … Comparison of two sequences (pp. 10-11) The CAD$270 million difference is attributable to different foreign currency capital loss amounts – a CAD$300 million foreign currency capital loss under the DIP financing settlement – bond settlement sequencing, versus a CAD$30 million foreign currency capital loss under the Bond settlement – DIP financing settlement sequencing. ...

Interpretation of "formed" (pp. 396 – 398) [T]he word “formed” appears to refer to a corporation that comes into existence as a result of the merger or combination, such as a corporation formed on an amalgamation. … [T]he Tax Court of Canada appears to have interpreted the word “formation" in a similar manner in … 1591141 Alberta …, 2014 TCC 2. … [E]ven if a winding up … could be considered a "merger" or a "combination" under a broad operational definition of those terms, it could not be a merger or combination described in subparagraph 40(3.5)(c)(i) because it does not result in the formation of a corporation…. ... These provisions include … subsections 87(1) and (8.1) … as well as…subsection 87(8.2)…. … The exclusion of windups in the "amalgamation" and "foreign merger" definitions does not mean that every winding up would otherwise be considered a merger or combination…. ... There is no indication that subparagraph 40(3.5)(c)(i) was meant to address windups. …. ...

The French translations at first correctly translated "on behalf of" as " ", but then, as a less adequate translation, started using " au nom de ", where the English original continued with "on behalf of". When the French version became the original language in the report to the Council, " au nom de " became the leading term and English followed with "in the name of". Although the Chairman of the Fiscal Committee pointed out that the French text erroneously referred to " au nom de ", this term, and the resulting "in the name of", was eventually approved....... ...

Kevin Yip, "Recent Legislation Affecting Partnerships and Foreign Affiliates – Subsection 88(1) and Section 100", Canadian Tax Journal, (2013) 61:1, 229-256, at 241-242-- summary under Subsection 5905(7) Summary Under Tax Topics- Income Tax Regulations- Regulation 5905- Subsection 5905(7) After noting that where property being bumped is an interest in a partnership holding foreign affiliate shares, proposed Reg. 5908(7) applies rather than proposed Reg. 5905(5.4)(a), and describing the formula in proposed Reg. 5908(7), he provided the following example: Example 2 – Facts Subsidiary is a corporation resident in Canada and holds a 50 percent interest in Partnership. ... The formula (A + B – C)/D in proposed regulation 5905(5.2) will apply as follows: A (FA's TFSB is $1,400 ($2,800 x 50% [Subsidiary's SEP in FA]). ... The reduction to FA's exempt surplus is $1,000 ([$1,400 + $300- $1,200]/0.50), but Subsidiary effectively has a reduction of only 50 percent of that amount ($500). ...