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2 May 1991 Ruling 9100893 F- Disposition of an Income Interest in a Trust- Disclaimer Unedited CRA Tags IT-385R 3-910089 Dear Sirs: Re; 19(1) 24(1) Advance Income Tax ruling This is further to your letters of December 31, 1990 and April 22, 1991 in respect to the above noted advance income tax ruling request. 24(1) Paragraph 6 of the Department's Information Circular IC 70-6R2, dated September 28, 1990, states that an advance ruling can not be provided on transactions that are already completed or on series of transactions that are significantly advanced.  ...

2 July 1991 Ruling 911291 F- International Shipping Corporations Unedited CRA Tags 81(1)(c), 250(6), 115(1), 5906(1)(b), 5907(1)(a), 95(2)(a)(ii)    911291                                              G. Arsenault                                             (613) 957-2126 July 2, 1991 Dear Sirs: Re:  International Shipping Corporations This is in reply to your letters dated May 6 and June 20, l99l concerning paragraph 81(1)(c) of the Canadian Income Tax Act (the "Act") and the proposed amendment of the Act by the addition of subsection 250(6) as described in Clause 194 of Bill C-18 tabled by the Minister of Finance on May 30, l99l (proposed subsection 250(6)"). ... Whether a particular asset is capital property used by a person in carrying on a business (other than an insurance business) in Canada such that the asset is "taxable Canadian property" by virtue of subparagraph 115(1)(b)(ii) of the Act is essentially a question of fact that can only be answered after determination and consideration of all relevant facts pertaining to the particular case under consideration. 2.      ...

2 July 1991 Ruling 911203 F- Disposition of Securities- Income vs Capital Unedited CRA Tags 85 24(1) 19(1) Re: Disposition of Securities- Income vs Capital This is in reply to your memorandum of April 17, 1991, requesting our opinion as to whether the   24(1)   by the taxpayers named above should be considered on behalf of income or capital. ...

2 April 1990 Ruling 74793 F- Employers Dealing at Arm's Length Unedited CRA Tags 251(1), 251(2), 251(6)   April 2, 1990 REGISTRATION DIRECTORATE FINANCIAL INDUSTRIES Registered Pension and DIVISION Deferred Income Plans Division Maureen Shea-DesRosierss (613) 957-8953 Mrs Stella Kotlar Director ATTENTION: MS. ...

It also owns XXXXXXXXXX% of FA 2 (being XXXXXXXXXX common shares of FA 2). 30. ... Redemptions of the Subco 2 Note and the Subco 3 Note 52. Can Holdco will pay to Subco 2 an amount in cash equal to the principal amount and FMV of the Subco 2 Note (the "Subco 2 Note Cash Payment") in full repayment and satisfaction of the Subco 2 Note. ... The resolution of the board of directors of Subco 2 to effect the Subco 2 Capital Reduction and the Subco 2 Distribution will specify that the amounts of the Subco 2 Capital Reduction and the Subco 2 Distribution are subject to an adjustment clause which will adjust the amounts of the Subco 2 Capital Reduction and the Subco 2 Distribution upward or downward depending on any adjustment to the amount of the Subco 2 Note Cash Payment, as described in Paragraph 52. ...

CanLP 2 45. CanLP 2 carries on a business in Canada that is included in Business Segment 2. 46. ... All Cansub 2 Retained Loans will be repaid in full to Cansub 2. Cansub 2 will retain ownership of the Cansub 2 Spin Loans. 156. ... Amalgamation 2 189. New Canco 1, New Canco 2 and DC ULC will amalgamate (the Amalgamation 2) under Act 2 to form New DC ULC. ...

Cansub 2 29. Cansub 2 carries on a business in Canada that is included in Business Segment 2. 30. ... CanLP 2 53. CanLP 2 carries on a business in Canada that is included in Business Segment 2. 54. ... Forsub 2 75. Forsub 2 carries on a business in Country 2 that is included in Business Segment 1. 76. ...

Prior to Closing Date #2, Vendor #2 (or Residents who were related persons with respect to Vendor #2) owned the Target Assets #2. ... The SPA #2 closed on Closing Date #2 and P #2 acquired all of the issued and outstanding Target Shares from Vendor #2. ... The reason why Bco transferred the I #2 to Subco #2 was to allow Subco #2 to distribute the I #2 to Aco (when Subco #2 is wound up into Aco in the future). ...

Subco will transfer the Subco Bco Shares to Newco 2. Newco 2 will issue Class XXXXXXXXXX common shares to Subco as the sole consideration for the Subco Bco Shares. ... Subsequent to the acquisition of the XXXXXXXXXX Bco Shares and the Subco Bco Shares by Newco 2, the directors of Newco 2 will, in respect of each class of shares of Newco 2, declare a series of stock dividends payable to the holder of shares of such class. ... Subsequent to the acquisition by Bco of all of the issued and outstanding Newco 2 shares, Bco, as sole shareholder of Newco 2, will commence the voluntary dissolution of Newco 2 XXXXXXXXXX. ...

Forco 2 47. Forco 2 is a XXXXXXXXXX established under the laws of Foreign Country 3. ... All of the Shares of Forco 2 are owned by Forco 1. Forco 2 is a FA and a CFA of Pubco and CanSub for the purposes of the Act. 49. ... Opco is a Non-Resident Corporation that is resident in Foreign Country 2 for the purposes of the Act and Treaty 2. 52. ...