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2014 Ruling 2013-0496831R3 - Irish Common Contractual Fund -- summary under Subsection 104(1)

Proposed transactions CCF, which is a "single strategy" fund under Part 2 of the Investment Funds Act, will extend its investments to equities of Canadian public companies and will accept investments from Canadian residents which are exempt under s. 149(1). ...

2014 Ruling 2013-0514191R3 - Debt restructuring, forgiveness and winding-up -- summary under Subsection 80.01(4)

Ss. 40(2)(e.1) and 53(1)(f.1) will apply to the note transfers in 2 so that the ACB to New ULC of the notes will be increased by an amount equal to the denied capital loss. ...

14 March 2014 Internal T.I. 2013-0499141I7 - IRC 338(h)(10), "earnings" and safe income -- summary under Paragraph 5907(2)(f)

(a)(i) of the "earnings" definition) – without duplication of the adjustments in 1 and 2. ...

2013 Ruling 2013-0504301R3 - Loss Consolidation -- summary under Paragraph 111(1)(a)

Newco will use the proceeds in 2 to make a non-interest-bearing loan to Lossco under the "Lossco Note. ...

11 December 2015 External T.I. 2015-0601561E5 F - Attribution Rules -- summary under Subsection 74.4(2)

X would not be considered, for purposes of subsection 74.4(2), to have indirectly transferred property to Holdco. 2 nd Situation. ...

8 December 2015 External T.I. 2015-0613401E5 F - Attribution Rules -- summary under Subsection 74.4(2)

…[W]e refer you to… 2002-0147325 …. 2 nd Situation. Same as 1 st situation except that, rather than subscribing for preferred shares of Holdco, Opco declares a dividend on its common shares (held by Mr. ...

15 June 2015 External T.I. 2014-0525501E5 - Royalty payments & the US or UK Treaties -- summary under Article 12

CRA concluded that the UK Treaty applied in the same way: [I]f Fee #2 were paid to an OwnerCo resident in the UK, it would fall into the definition of “royalties” in paragraph 4 of Article 12 of the UK Treaty. ...

2015 Ruling 2014-0532201R3 - Corporate reorganization -- summary under Paragraph 38(a.1)

Trust 2 owns common shares of Corporation 18, a CCPC, and the balance of the shares of Corporation 18 are owned by Corporation 25. ...

10 June 2016 STEP Roundtable Q. 1, 2016-0634871C6 - GREs and Testamentary Trusts -- summary under Graduated Rate Estate

We reiterated that general position in question 2 at last year’s Roundtable. ...

27 January 2017 External T.I. 2013-0482351E5 - Clause 95(2)(a)(ii)(D) -- summary under Clause 95(2)(a)(ii)(D)

In responding favourably, CRA itemized four requirements of Clause D, of which the following three required most of the analysis: (2) the penalty received by FA Finco is an amount paid or payable by FA Holdco “under a legal obligation to pay interest on borrowed money;” (3) the penalty received by FA Finco is an amount paid or payable by FA Holdco “in respect of any particular period in the year;” and (4) the borrowed money is used for the purpose of earning income from property that is shares of a foreign affiliate. ...

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