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2021 Ruling 2020-0868661R3 F- Section 84.1 – Leveraged Buyout-- summary under Subsection 84.1(1) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(1) s. 84.1 did not apply to a leveraged buyout financed by the target Background Holdco (a.k.a. ...

2018 Ruling 2017-0711071R3- Use of subsidiary losses & ITCs after wind-up-- summary under Paragraph 88(1.1)(b) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1.1)- Paragraph 88(1.1)(b) streamed losses of empty-shell Lossco flowed through on its dissolution as Lossco LP business had been acquired years earlier through sub LP Acquisition of Lossco business Subsequently to a CCAA filing by Lossco and members of its group, Taxpayer (a wholly-owned subsidiary of a Luxembourg company held by a group of (perhaps U.S.) investors), as limited partner, and its wholly-owned subsidiary, as GP, formed Lossco Business LP, which then acquired the business (the "Lossco Business”) of Lossco pursuant to the “Asset Sale Agreement”. ...

2020 Ruling 2019-0799981R3- Disposition – Reclassification and Stock Split-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition a simultaneous consolidation of 7 identical series of common shares into 1 series, and a stock split, did not effect a disposition Current structure USco is a US-resident corporation that is subject to tax in Canada and the US (in each case, as a regarded corporation). ...

2013 Ruling 2012-0467721R3- IV(7)(b) & PUC increase-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 two-step distribution to two S-Corp shareholders of ULC/interest payment to one USCo and USCo2 are each S Corporations whose shares are owned in the same proportions by U.S. ...

2016 Ruling 2015-0571441R3- Dutch Cooperative- 93.2 & 95(2)(c)-- summary under Paragraph 95(2)(c) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(c) rollover is available on joint drop-down of shares of a Dutch private limited liability company into a Dutch cooperative in consideration for respective credits to the membership accounts Current structure Forco 1 is held through three stacked Canadian partnerships by two taxable Canadian corporations (Canco 1D and Canco 1A) which, in turn, are indirect wholly-owned subsidiaries of a non-resident parent (“Parent”). ...

For example: The RestaurantCo certificate offers discounts at […] locations in […] [Participating Province X]. ... The certificate has a value of over $[…] and is sold for $19.99. It has four components: A single use [dining] offer of a […]% discount on food total (maximum value $[…]) […] free dinner entrees: Buy one, get one […] free lunch entrees: Buy one, get one Purchaser will receive $[…] in RestaurantCo cash with every catered order over $[…] CRA rules that the certificates are not gift certificates for GST purposes, as they do not have a monetary value. ...

2004 Ruling 2004-007680-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) // www.bci.ca/ "> www.bci.ca): Non-capital losses of BCI are transferred to its affiliate, Bell Canada, pursuant to transactions under which a subsidiary of Bell Canada ("Bell Subco") borrows up to $17 billion on a day-light loan and uses the borrowed money to subscribe for preferred shares of a newly-incorporated subsidiary of BCI ("BCI Subco"), BCI Subco lends the money on a non-interest bearing basis to BCI, BCI lends the same funds on an interest-bearing basis (1 basis point lower than the dividend rate on the preferred shares) to Bell Subco, which pays off the day-light loan. ...

2004 Ruling 2004-007680-- summary under Paragraph 12(1)(x) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) contributions of capital // www.bci.ca/ "> www.bci.ca): Non-capital losses of BCI are transferred to its affiliate, Bell Canada, pursuant to transactions under which a subsidiary of Bell Canada ("Bell Subco") borrows up to $17 billion on a day-light loan and uses the borrowed money to subscribe for preferred shares of a newly-incorporated subsidiary of BCI ("BCI Subco"), BCI Subco lends the money on a non-interest bearing basis to BCI, BCI lends the same funds on an interest-bearing basis (1 basis point lower than the dividend rate on the preferred shares) to Bell Subco, which pays off the day-light loan. ...

CRA ruled that s. 95(2)(a)(i) deemed the income of one of the FA5 Subsidiaries to be active business income, and an addition to its exempt surplus under Reg. 5907(1) – exempt earnings – s. ... Here, FA4 also held distressed debt portfolios of its own, albeit partly through a subsidiary LP – and one of the conditions for the CRA ruling was that LP qualified as a partnership for ITA purposes. ...

The New Trust will not file an election under s. 248(1) – disposition – para. (f) – subpara. (v) for that para. not to apply. Subsequent transactions Prior to the Winding-up Date, the Initial Trustee will exercise his discretionary power pursuant to the Deed of Trust for the New Trust for making an advance determination of the portions of the trust capital and income which will be distributed among Mr. ...