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He will be a shareholder and director of Newco and will establish a corporation ("XXXXXXXXXX ") that will become a Contracting Company. 33. ...

ADMINISRATIVE MATTERS: The taxpayers' names and Social Insurance Numbers / Business Numbers are as follows: XXXXXXXXXX /Mother XXXXXXXXXX XXXXXXXXXX /Child 1 XXXXXXXXXX XXXXXXXXXX GROUP Related and Associated Companies XXXXXXXXXX /Aco XXXXXXXXXX XXXXXXXXXX /Bco XXXXXXXXXX XXXXXXXXXX. ...

., B Co. and other persons related to A Co. for purposes of the Act.have generally participated in approximately XXXXXXXXXX % of the funding for XXXXXXXXXX joint venture program. 7. ...

Each of the following corporations is a Canadian corporation, TCC and private corporation: Corporate Name Date incorporated Account # XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX All the above companies were incorporated in XXXXXXXXXX and file their corporate income tax returns at the XXXXXXXXXX Taxation Centre. ...

Under the 1998 Indenture, the following will be Events of Default: a) the failure to pay principal (including any Additional Amounts) or premium on any 1998 Note when due b) failure to pay interest (including any Additional Amounts) on any 1998 Note when due continued for thirty days; c) default in the payment of principal and interest (including any Additional Amounts) on 1998 Notes required to be purchased pursuant to an Offer to Purchase in respect of a Change of Control as described in paragraphs 19 and 20 above, or in respect of the limitation on certain asset dispositions described in paragraph 16 above, when due and payable, or failure to make an Offer to Purchase as required; d) failure to comply with the 1998 Indenture provisions relating to mergers, consolidations, asset sales described in paragraph 21 above; e) failure to perform any other covenant or agreement of ACO under the 1998 Indenture or the 1998 Notes continued for 60 days after written notice to ACO by the Trustees or holders of at least XXXXXXXXXX % in aggregate stated principal amount of outstanding 1998 Notes; f) default under the terms of any instrument evidencing or securing debt by ACO or any of its subsidiaries having an outstanding principal amount of XXXXXXXXXX individually or in the aggregate, which default results in the acceleration of the payment of such indebtedness or constitutes the failure to pay such indebtedness when due g) the rendering of a final judgment or judgments (not subject to appeal) against ACO or certain of its subsidiaries in an amount in excess of XXXXXXXXXX which remains undischarged or unstayed for a period of 60 days after the date on which the right to appeal has expired; and h) certain events of bankruptcy, insolvency or reorganization affecting ACO or certain of its subsidiaries, 25. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayers or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...

.), c.1, as amended (the "Act"); (b) "ACB" means "adjusted cost base" as that expression is defined in section 54 and subsection 248(1); (c) "arm's length" has the meaning assigned by subsection 251(1); (d) "BCA" means the Business Corporations Act XXXXXXXXXX as amended; (e) "capital property" has the meaning assigned by section 54; (f) "cost amount" has the meaning assigned by subsection 248(1); (g) "disposition " has the meaning assigned by section 54; (h) "financial institution" has the meaning assigned by subsection 142.2(1) (i) "ineligible property" has the meaning assigned by paragraph 88(1)(c); (j) "investment dealer" has the meaning assigned by subsection 142.2(1); (k) "mark-to-market property" has the meaning assigned by subsection 142.2(1); (l) "PUC" means paid-up capital as that expression is defined in subsection 89(1); (m) "registered securities dealer" has the meaning assigned by subsection 248(1); (n) "proceeds of disposition" has the meaning assigned by section 54; (o) "public corporation" has the meaning assigned by subsection 89(1); (p) "related persons" has the meaning assigned by subsection 251(2); (q) "safe income on hand" in respect of particular shares of a corporation at a particular time refers to the income earned or realized, within the meaning of paragraphs 55(5)(b) or (c), by any corporation after 1971 and before the safe-income determination time to the extent that it is on hand and can reasonably be considered to contribute to the capital gain that would be realized on a disposition at fair market value of the particular share of the corporation; (r) "safe income determination time" has the meaning assigned by subsection 55(1); (s) "stated capital" has the meaning assigned by XXXXXXXXXX of the BCA; (t) "subsidiary wholly-owned corporation" has the meaning assigned by subsection 248(1); and (u) "taxable Canadian corporation" has the meaning assigned by subsection 89(1). ...

(iii) OPCO devra payer à PUBLICO des redevances annuelles correspondant au plus élevé de: (a) XXXXXXXXXX $ et (b) coût de maintien des marques de commerce plus XXXXXXXXXX%. ...

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 the foreign affiliate shares to amount of the transfer. (2) The transactions are not a misuse or abuse of the Act or its provisions. (3) The “one of the main purposes” condition has not been met. ...

2020 Ruling 2020-0860231R3- Post-mortem planning Unedited CRA Tags 84(2), 84.1, 88(1), 245(2) * Principal Issues: Post-mortem pipeline and bump transaction ruling Position: Favourable rulings issued. ...