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2013 Ruling 2013-0475701R3- MIC deemed interest & participating debt interest-- summary under Participating debt interest Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(3)- Participating debt interest applies to dividends deemed to be interest The Corporation, a "mortgage investment corporation" under s. 130.1(6), pays dividends which take into account, inter alia, its income and financial conditions. ...

1999 Ruling 9903543- TOTAL RETURN SWAPS & MUTUAL FUND TRUST-- summary under Subsection 18.1(15) Summary Under Tax Topics- Income Tax Act- Section 18.1- Subsection 18.1(15) An open-end unit trust invests the proceeds of a public offering in a note of a bank and then enters into a total-return swap with the Bank respecting a bond index (some of the components of which correspond to bonds held by the bank). ...

2020 Ruling 2019-0799981R3- Disposition – Reclassification and Stock Split-- summary under Subsection 116(1) Summary Under Tax Topics- Income Tax Act- Section 116- Subsection 116(1) no s. 116 certificate required for simultaneous consolidation of multiple identical series into one series, and stock split With a view to going public, a closely-held US corporation, whose issued and outstanding shares (which were taxable Canadian property and held by Canadian and US-resident corporate shareholders) consisted of seven series of common shares with identical attributes, proposed to amend its articles of incorporation so as to reclassify all the common shares into one series and to simultaneously effect a stock split. ...

2012 Ruling 2010-0355941R3- reverse subsidiary merger- 87(1) & 87(11)-- summary under Subsection 87(11) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(11) survivor style amalgamation on Code reverse triangular merger Under a BC plan of arrangement, a BC corporation ("SubcoTarget") is merged with its wholly-owned BC subsidiary ("Target") to form "Amalco" with the same effect as if they had amalgamated under section 269 of the Business Corporations Act (BC), except that the legal existence of Target does not cease and it survives the merger, Subco ceases to exist and the property of Subco (other than its shares of Target, which are cancelled) become the property of Target. ...

2012 Ruling 2010-0355941R3- reverse subsidiary merger- 87(1) & 87(11)-- summary under Subsection 87(1) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(1) reverse triangular "E" merger- survivor style amalgamation Under a BC plan of arrangement, a BC corporation ("SubcoTarget") is merged with its wholly-owned BC subsidiary ("Target") to form "Amalco" with the same effect as if they had amalgamated under section 269 of the Business Corporations Act (BC), except that the legal existence of Target does not cease and it survives the merger, Subco ceases to exist and the property of Subco (other than its shares of Target, which are cancelled) become the property of Target. ...

2011 Ruling 2011-0416891R3- Fees for Digital Content & Management Services-- summary under Paragraph 212(4)(a) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(4)- Paragraph 212(4)(a) management of on-line store A US LLC ("Corporation C"), whose sole member was a US corporation qualifying for benefits under the Canada-US Convention, ran a platform for the provision of "Digital Content" (movies, television shows, music videos, documentaries and similar audio-visual content) which it (and affiliated corporations) were permitted to distribute under content licence agreements with the third-party holders of the copyright. ...

2011 Ruling 2011-0416891R3- Fees for Digital Content & Management Services-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 A US LLC ("Corporation C"), whose sole member was a US corporation qualifying for benefits under the Canada-US Convention, ran a platform for the provision of "Digital Content" (movies, television shows, music videos, documentaries and similar audio-visual content) which it (and affiliated corporations) were permitted to distribute under content licence agreements with the third-party holders of the copyright. ...

2016 Ruling 2015-0571441R3- Dutch Cooperative- 93.2 & 95(2)(c)-- summary under Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Corporation Dutch cooperative whose articles limited member liability was a corp Before ruling that the contribution of shares of a Netherlands private limited liability company to a newly-formed Netherlands cooperative (Dutch Co-op, or "DC"), in consideration for a credit to the membership accounts of the contributing foreign affiliates, was eligible for s. 95(2)(c) rollover treatment, CRA ruled that DC was a corporation for the purposes of the Act, and a non-resident corporation without share capital for purposes of s. 93.2. ...

2016 Ruling 2015-0571441R3- Dutch Cooperative- 93.2 & 95(2)(c)-- summary under Controlled Foreign Affiliate Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(1)- Controlled Foreign Affiliate non-resident subsidiaries CFAs of bottom-tier Cdn partnership and FAs of Canadian corporate partners Forco 1 is held through three stacked Canadian partnerships (the bottom one, “CanGP 3”) by two taxable Canadian corporations (Canco 1D and Canco 1A) which, in turn, are indirect wholly-owned subsidiaries of a non-resident parent (“Parent”). ...

2018 Ruling 2017-0711071R3- Use of subsidiary losses & ITCs after wind-up-- summary under Paragraph 88(1)(e.3) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(e.3) purchaser could acquire Lossco’s business through a sub LP and then acquire Lossco, accessing s. 88(1)(e.3) A foreign-owned Canadian-resident corporation (“Taxpayer”) used a subsidiary LP to acquire the sole business of a “Lossco” that was in CCAA proceedings and then, a number of years later (and perhaps well after the completion of the CCAA restructuring) it purchases the shares of Lossco for nominal consideration and winds up Lossco. ...