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Newco 2 will be entitled to cumulative dividends on the Newco 1 Preferred Shares calculated daily by reference to the redemption / retraction price of the Newco 1 Preferred Shares. ...

The significant assets of DC include accounts receivable, XXXXXXXXXX account, prepaid expenses and inventory (XXXXXXXXXX), equipment & vehicles, a XXXXXXXXXX and land and buildings (including XXXXXXXXXX personal residences situated on land owned by DC as well as XXXXXXXXXX rental properties). ...

DEFINITIONS “ACB” means “adjusted cost base” and has the meaning assigned by section 54; “Aco” means XXXXXXXXXX, the corporation described in Paragraph 3; “affiliated person” has the meaning assigned by section 251.1, read without reference to the definition of “controlled” in subsection 251.1(3); “arm’s length” has the meaning assigned by subsection 251(1); “BCA1” means XXXXXXXXXX; “BCA2” means XXXXXXXXXX; “Bco” means XXXXXXXXXX, the corporation described in Paragraph 4; “CRA” means Canada Revenue Agency; “cost amount” has the meaning assigned by subsection 248(1); “Daylight Loan” means a loan made by a third party financial institution to Lossco, as described in Paragraph 33; “dividend rental arrangement” has the meaning assigned by subsection 248(1); “excepted dividend” has the meaning assigned by section 187.1; “excluded dividend” has the meaning assigned by subsection 191(1); “FMV” or “fair market value” means the highest price available in an open and unrestricted market between informed and prudent parties dealing at arm’s length and under no compulsion to act, expressed in terms of cash; “financial institution” has the meaning assigned by subsection 190(1); “forgiven amount” has the meaning assigned by subsections 80(1) and 80.01(1); “guarantee agreement” has the meaning assigned by subsection 112(2.2); “IB Loan” means, in the singular, the interest bearing loan made by Lossco to Profitco described in Paragraph 34 and, in the plural, all of the IB Loans resulting from the transactions described in Paragraph 37(a); “ IB Note” means the promissory note described in Paragraph 37(a); “Implementation Date” means XXXXXXXXXX; “Intercompany Debts” means the debts existing between Lossco as creditor and Numberco as debtor, as described in Paragraph 14; “Lossco” means XXXXXXXXXX, the corporation described in Paragraph 5; “Loss Consolidation Arrangement” means the transactions described in Paragraphs 32 to 42; “NIB Loan” means, in the singular, the non-interest bearing loan described in Paragraph 36 and in the plural, all of the NIB Loans resulting from the transactions described in Paragraph 37(c); “NIB Note” means the demand non-interest bearing promissory note described in Paragraph 37(c); “non-capital loss” has the meaning assigned by subsection 111(8); “Numberco” means XXXXXXXXXX, the corporation described in Paragraph 13, which, as described in Paragraph 30, will be continued under the BCA1 and converted to an unlimited liability company with the legal name XXXXXXXXXX (or such other legal name as may be selected and permitted); “Numberco Capitalization” mean the contribution of capital described in Paragraph 39(a); “Numberco Preferred Shares” means the preferred shares of Numberco described in Paragraph 31; “PUC” means “paid-up capital” and has the meaning assigned by subsection 89(1); “Paragraph” means a numbered paragraph in this letter; “principal amount” has the meaning assigned by subsection 248(1); “private corporation” has the meaning assigned by subsection 89(1); “Profitco” means XXXXXXXXXX, the corporation described in Paragraph 9; “Proposed Transactions” means the transactions described in Paragraphs 29 to 42; “related persons” has the meaning assigned by subsection 251(2); “Redemption Amount” of a Numberco Preferred Share has the meaning described in Paragraph 35; “Rulings” means the advance income tax rulings labelled “A” to “K” in this letter; “specified financial institution” has the meaning assigned by subsection 248(1); “stated capital” means the amount of capital determined in respect of a class or series of shares in accordance with the governing legislation of the corporation; “substantial interest” has the meaning assigned by subsection 191(2); “Solvency Capitalization” means the contribution of capital described in Paragraph 29; “Support Agreement” means the agreement described in Paragraph 39(a); “taxable Canadian corporation” has the meaning assigned by subsections 89(1) and 248(1); “taxable dividend” has the meaning assigned by subsections 89(1) and 248(1); “Tax Collection Agreement” is an agreement that has been entered into between a province and the Government of Canada; “taxable preferred share” has the meaning assigned by subsection 248(1); “Taxpayers” mean the entities described on page 1 of this letter; “Ultimate Parent” means XXXXXXXXXX, the corporation described in Paragraph 1; and XXXXXXXXXX. ...

XXXXXXXXXX 2022-094120 XXXXXXXXXX, 2022 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling – Loss Consolidation Arrangement (2022-094120) XXXXXXXXXX This is in reply to your letter dated XXXXXXXXXX, as amended XXXXXXXXXX, in which you requested an advance income tax ruling (the “Ruling”) on behalf of the above named taxpayers (the “Taxpayers”). ...

The TSO, taxation centre ("TC"), and the Revenue Canada account number ("RCT #") of the various members of XXXXXXXXXX are as follows: Corporation TSO\TC RCT # XXXXXXXXXX 11. ...

These shares were subsequently transferred to the Senior Trust – an alter ego trust. ...

Provided that immediately after the Proposed Transactions REIT # 1 shall own all of the assets that Taxpayer previously owned, directly or indirectly, immediately before the Proposed Transactions, the provisions of subsections 15(1), 56(2), 56(4), 69(1), 69(4), 105(1) and 246(1) will not apply as a result of the Proposed Transactions, in and by themselves. ...

The FMV of the marketable security portfolio held by DC is approximately $XXXXXXXXXX and of that, over XXXXXXXXXX % represents shares held in the capital stock of Investco A, Investco B, and Investco C. 2. ...

2006 Ruling 2006-0178401R3- 132.2 reorganization of a mutual fund trust Unedited CRA Tags 132.2 97(2) 85(1) 253.1 Principal Issues: Reorganization of an existing mutual fund trust, trust- on-corporation structure to a trust-on-partnership structure using rollovers available under s. 85, s.97 and 132.2; Additional issues encountered include deductibility of interest; debt forgiveness; acb of partnership interest & status of the mutual fund trust. ...

The fair market value, immediately before the Spin-off described in Paragraph 59, of each Participant's shares of the capital stock of Spinco will be equal to the amount determined by the formula: (A x B/C) + D as set out in subparagraph (b)(iii) of the definition "permitted exchange" in subsection 55(1). ...