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Reasons: (1) Ruling granted previously in similar circumstances- transaction not to confer benefit – in particular, transaction at less than FMV permitted tax deferred transaction with restriction of ACB of FA1 shares to amount transferred for. (2) The transactions are not a misuse or abuse of the Act or its provisions. There is no avoidance of income tax achieved, only a deferral – not clear that policy of Act intended to deny deferral in these circumstances. ...

2020 Ruling 2020-0865971R3- Loss consolidation arrangement Unedited CRA Tags 20(1)(c), 55(2) * Principal Issues: Whether the LCA is acceptable Position: Yes Reasons: The proposed transactions fall within CRA's policy position XXXXXXXXXX 2020-086597 XXXXXXXXXX, 2020 Dear XXXXXXXXXX: Subject: Advance Income Tax Ruling XXXXXXXXXX We are writing in response to your letter of XXXXXXXXXX and revised letter of XXXXXXXXXX wherein you requested an advance income tax ruling on behalf of the above-referenced taxpayers. ... Opco will use the proceeds of the Daylight Loan to make a loan of the same amount, $XXXXXXXXXX, bearing interest at the estimated rate of XXXXXXXXXX % per annum to Lossco (the "Lossco Loan"). ...

In May 2014, the NEB issued the MH-001-2013 Reasons for Decisions – Set-aside and collection mechanisms (Pipeline Abandonment- Financial Issues) (the “SAM/COM Decision”), which required certain NEB-regulated pipeline companies to have a set-aside mechanism in place by January 1, 2015, and to begin accumulating funds to pay for pipeline reclamation. 4. ... Yours truly, XXXXXXXXXX Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

In May 2014, the NEB issued the MH-001-2013 Reasons for Decisions – Set-aside and collection mechanisms (Pipeline Abandonment- Financial Issues) (the “SAM/COM Decision”), which required certain NEB-regulated pipeline companies to have a set-aside mechanism in place by January 1, 2015, and to begin accumulating funds to pay for pipeline reclamation. 4. ... Yours truly, XXXXXXXXXX Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

In May 2014, the NEB issued the MH-001-2013 Reasons for Decisions – Set-aside and collection mechanisms (Pipeline Abandonment- Financial Issues) (the “SAM/COM Decision”), which required certain NEB-regulated pipeline companies to have a set-aside mechanism in place by January 1, 2015, and to begin accumulating funds to pay for pipeline reclamation. 7. ... Yours truly, XXXXXXXXXX Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

In May 2014, the NEB issued the MH-001-2013 Reasons for Decisions – Set-aside and collection mechanisms (Pipeline Abandonment- Financial Issues) (the “SAM/COM Decision”), which required certain NEB-regulated pipeline companies to have a set-aside mechanism in place by January 1, 2015, and to begin accumulating funds to pay for pipeline reclamation. 4. ... Yours truly, XXXXXXXXXX Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

Immediately prior to the time of the Deceased’s death, there were XXXXXXXXXX Opco Common Shares, XXXXXXXXXX Opco Class A Preference Shares, XXXXXXXXXX Opco Class B Preference Shares, XXXXXXXXXX Opco Class C Preference Shares, XXXXXXXXXX Opco Class D Preference Shares, XXXXXXXXXX Opco Class E Preference Shares, XXXXXXXXXX Opco Class F Preference Shares, XXXXXXXXXX Opco Class G Preference Shares, XXXXXXXXXX Opco Class A Special Shares and XXXXXXXXXX Opco Class B Special Shares, issued and outstanding, which were owned, and which had a FMV, ACB and PUC, as set forth below: Shareholder Number & Class FMV ACB PUC of Shares of Opco Deceased XXXXX Opco Common XXXXX XXXXX XXXXX Shares Deceased XXXXX Opco Class A XXXXX XXXXX XXXXX Preference Shares Deceased XXXXX Opco Class B XXXXX XXXXX XXXXX Preference Shares Deceased XXXXX Opco Class C XXXXX XXXXX XXXXX Preference Shares Deceased XXXXX Opco Class D XXXXX XXXXX XXXXX Preference Shares Deceased XXXXX Opco Class F XXXXX XXXXX XXXXX Preference Shares Deceased XXXXX Opco Class G XXXXX XXXXX XXXXX Preference Shares Deceased XXXXX Opco Class A XXXXX XXXXX XXXXX Special Shares Deceased XXXXX Opco Class B XXXXX XXXXX XXXXX Special Shares Child 1 XXXXX Opco Class B XXXXX XXXXX XXXXX Preference Shares Child 1 XXXXX Opco Class G XXXXX XXXXX XXXXX Preference Shares Child 1 XXXXX Opco Class B XXXXX XXXXX XXXXX Special Shares Child 2 XXXXX Opco Class B XXXXX XXXXX XXXXX Preference Shares Child 2 XXXXX Opco Class G XXXXX XXXXX XXXXX Preference Shares Child 2 XXXXX Opco Class B XXXXX XXXXX XXXXX Special Shares Holdco XXXXX Opco Class E XXXXX XXXXX XXXXX Preference Shares On XXXXXXXXXX, Child2 transferred all of XXXXXXXXXX shares of Opco to a corporation controlled by Child2, in which the Estate has no interest. ... As a consequence, under subsection 70(5) of the Act, immediately before his death the Deceased was deemed to have disposed of the shares of Opco owned by him, and the Estate was deemed to have acquired such shares, at the FMV of such shares as set forth below: Number & Class of Shares of Opco FMV Immediately owned by the Deceased Before the Deceased Death XXXXX Opco Common Shares XXXXX XXXXX Opco Class A Preference Shares XXXXX XXXXX Opco Class B Preference Shares XXXXX XXXXX Opco Class C Preference Shares XXXXX XXXXX Opco Class D Preference Shares XXXXX XXXXX Opco Class F Preference Shares XXXXX XXXXX Opco Class G Preference Shares XXXXX XXXXX Opco Class A Special Shares XXXXX XXXXX Opco Class B Special Shares XXXXX 7. ...

P-Note 2 will be due within three years of the closing of the Proposed Transactions; “PUC” means “paid-up capital” as that term is defined in subsection 89(1) of the Act; “Proposed Transactions” means the transactions described in Paragraphs 45 to 54; “related person”, or persons related to each other, has the meaning assigned by subsection 251(2); “Safe Income” means, with respect to a taxable dividend described in paragraph 55(2.1)(a) that is received by a dividend recipient from a dividend payer, the amount of income earned or realized by a corporation — after 1971 and before the safe income determination time with respect to the transaction, event or series of transactions or events — that could reasonably be considered to contribute to the capital gain that would have been realized upon a disposition at FMV, made immediately before the dividend, of the share on which the dividend was received; “Sequential Butterflies” means the First Butterfly, the Second Butterfly and the Third Butterfly, referred to collectively; “TCC” means “taxable Canadian corporation” and has the meaning assigned by subsection 89(1); “Tco” means XXXXXXXXXX, a public corporation created under the BCA3, the shares of which are publicly traded; “Xco” means XXXXXXXXXX, a corporation incorporated under the BCA1, as described in Paragraph 163 of the Initial Ruling; “Yco” means XXXXXXXXXX, a corporation incorporated under the BCA1, as described in Paragraph 170 of the Initial Ruling; “Yco Management Employee 1” is an individual resident in Canada for the purposes of the Act who owns shares in a holding corporation owning shares in Yco and who also owns shares directly in Yco; “Yco Management Employee 2” means an employee of Yco who is an individual resident in Canada for the purposes of the Act and who is not related to Yco; “Yco Management Employee 3” means an employee of Yco who is an individual resident in Canada for the purposes of the Act and who is not related to Yco; “Yco Management Employee 4” means an employee of Yco who is an individual resident in Canada for the purposes of the Act and who is not related to Yco; “Yco Management Employee 5” means an employee of Yco who is an individual resident in Canada for the purposes of the Act and who is not related to Yco; and “Yco Management Employee 6” means an employee of Yco who is an individual resident in Canada for the purposes of the Act and who is not related to Yco. ...

Provided that, as part of the series of transactions or events that includes the proposed transactions, there is not: \* MERGEFORMAT \* MERGEFORMAT (i) a disposition of property in the circumstances described in subparagraph 55(3.1)(b)(i); (ii) an acquisition of control in the circumstances described in subparagraph 55(3.1)(b)(ii); or (iii) an acquisition of property in the circumstances described in paragraph 55(3.1)(c) or (d); which has not been described herein, then by virtue of paragraph 55(3)(b), subsection 55(2) will not apply to the taxable dividends referred to in the rulings given in I and K above and, for greater certainty, subsection 55(3.1) will not apply to deny the exemption under paragraph 55(3)(b). ...

The aggregate FMV, immediately before the Distribution, of the Foreign Spinco Common Shares owned by Foreign Services will be equal to or approximate the amount determined by the formula: (A × B/C) + D as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1) on the assumption that Foreign Services is the participant, DC is the distributing corporation and Foreign Spinco is the acquiror. ...