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Ruling

2004 Ruling 2004-0082691R3 - Public Company spin-off

., through its XXXXXXXXXX subsidiary, XXXXXXXXXX ("International Ltd"), owns approximately XXXXXXXXXX % of the shares of XXXXXXXXXX ("Z Limited"), a corporation incorporated under the laws of XXXXXXXXXX whose shares are listed on the XXXXXXXXXX Stock Exchange. X Co. and International Ltd. entered into an agreement dated XXXXXXXXXX with XXXXXXXXXX., which represented the registered holders of XXXXXXXXXX shares of Z Limited, to purchase approximately XXXXXXXXXX % shares of Z Limited. ... The interest rate in respect of Tranche A is fixed at XXXXXXXXXX % and in respect of Tranche B fluctuates with the prime lending rate in the Country G money market (XXXXXXXXXX% at XXXXXXXXXX). ...
Ruling

2004 Ruling 2004-0085771R3 - Public Company spin-off - FAPI consequences

X Co. and International Ltd. entered into an agreement dated XXXXXXXXXX with XXXXXXXXXX, which represented the registered holders of XXXXXXXXXX shares of Z Limited, to purchase approximately XXXXXXXXXX % shares of Z Limited. ... XXXXXXXXXX "), XXXXXXXXXX ("X Co. Management Services Country G (Pty) Ltd. ... Yours truly, XXXXXXXXXX Section Manager International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch [S1]This information creates confusion and we prefer to leave it out. ...
Ruling

2004 Ruling 2004-0096661R3 - 55(3)(a)

Jco's assets include (a) a XXXXXXXXXX% limited partnership interest in LP2 (the remaining XXXXXXXXXX % is owned by an arm's length person to Jco); and (b) a receivable owing by LP3. ... Ico and its XXXXXXXXXX subsidiary wholly-owned corporation, Lco (which was governed by the laws of XXXXXXXXXX) owned approximately XXXXXXXXXX% and XXXXXXXXXX % of the issued and outstanding common shares of Gco, respectively. ... Newco will use those loan proceeds to purchase the following receivables and partnership interest from Jco, LP1 and Aco: (a) receivable owing by LP3 to Jco described in paragraph 6 above; (b) receivable owing by LP2 to LP1 described in paragraph 3 above; (c) receivable owing by LP5 to Aco described in paragraph 3 above; and (d) Aco's XXXXXXXXXX % LP4 limited partnership interest described in paragraph 3 above. ...
Ruling

2022 Ruling 2022-0941371R3 - Post-mortem tax planning

The FMV, ACB and PUC of those shares immediately before the Deceased’s death are set forth below: Number & Class of FMV ACB PUC Shares of Holdco XXXXX Holdco Non-voting XXXXX XXXXX XXXXX Common Shares XXXXX Holdco Voting XXXXX XXXXX XXXXX Common Share 9. ... Immediately before the Deceased’s death, there were XXXXXXXXXX Opco Common Shares and XXXXXXXXXX Opco Class A Preference Shares issued and outstanding, which were owned, and which had an ACB, FMV and PUC, as set forth below: Shareholder Number & Class of FMV ACB PUC Shares of Opco Holdco XXXXX Opco Class A XXXXX XXXXX XXXXX Preference Shares Holdco XXXXX Opco Common XXXXX XXXXX XXXXX Shares Childco XXXXX Opco Common XXXXX XXXXX XXXXX Shares 11. ... Opco Class X Preference Shares with PUC and ACB equal to $XXXXXXXXXX the aggregate number and aggregate redemption value (the “Opco X Redemption Value”) of such shares to be determined immediately before the exchange; and ii. ...
Ruling

2007 Ruling 2007-0245281R3 - windup of income trust on sale of assets:3rd party

The following terms have the meanings specified: "Bidco" means XXXXXXXXXX, a taxable Canadian corporation that was incorporated in XXXXXXXXXX and, a wholly owned subsidiary of Subco; "Circular" means the take-over bid Circular dated XXXXXXXXXX accompanying the Offer and forming part of the Offer; "Compulsory Acquisition" means the forced acquisition of Units of Dissenting Unitholders in accordance with section XXXXXXXXXX of the Declaration of Trust; "Declaration of Trust" means the declaration of trust governing the Fund dated XXXXXXXXXX, as amended and restated as of XXXXXXXXXX, and as amended from time to time; "Dissenting Unitholder" means a Unitholder who does not deposit his or her Units under an offer to purchase Units; "Fund Third Party Debt" means the amount owed by the Fund to third party lenders immediately before the proposed transaction as described in paragraph 8 below; "Fund" means XXXXXXXXXX an unincorporated, limited purpose trust established under the laws of the XXXXXXXXXX and its head office is located at XXXXXXXXXX; "GPCo" means XXXXXXXXXX, the general partner of the Partnership; "Lock-up Agreements" means the lock-up agreements each dated XXXXXXXXXX among Bidco, Subco and XXXXXXXXXX on the one hand, and among Bidco, Subco and XXXXXXXXXX on the other hand; "Newco" means the one or more taxable Canadian corporations that the Partnership will create and wholly-own, and through which it will operate its business, as referred to in paragraph 30(a); "Normal Growth Guidelines" means the Guidance Provided on "Normal Growth" for Income Trusts and Other Flow-Through Entities issued in a press release by the Department of Finance on December 15, 2006; "Note" means the demand non-interest bearing promissory note that will be issued by Bidco to the Fund as partial consideration for the sale of the Fund's assets as described in paragraph 28(d) below; XXXXXXXXXX; "Notice to Dissenting Unitholders" means the notice that may be given under section XXXXXXXXXX of the Declaration of Trust to Dissenting Unitholders by a person making an offer to purchase Units in order to force a Compulsory Acquisition; "Offer" means the offer dated XXXXXXXXXX made by Bidco (as amended by the Notice of Variation and Extension) to acquire all of the outstanding Units; "Parent" means XXXXXXXXXX, a taxable Canadian corporation that was incorporated under and governed by the XXXXXXXXXX; "Partnership Agreement" means the partnership agreement governing the Partnership dated XXXXXXXXXX, as amended and restated as of XXXXXXXXXX and as amended from time to time; "Partnership" means XXXXXXXXXX, a limited partnership established under the laws of the XXXXXXXXXX that is governed by the Partnership Agreement and the Partnership is presently, and will continue to be, a "Canadian partnership", within the meaning of that term in subsection 102(1), until it ceases to exist; "Residual Amount" means the amount equal to the difference between the face value of the Note and the amount of the capital gain made payable to Bidco as described in paragraph 28(e) below; "SIFT Partnership" means a "specified investment flow-through partnership" as that term is defined in subsection 197(1); "SIFT Trust" means a "specified investment flow-through trust" as that term is defined in subsection 122.1(1); "Special Resolution" means a resolution adopted by Unitholders at a special meeting of Unitholders and passed by the affirmative votes of the holders of at least XXXXXXXXXX% of the Units represented at such meeting or approved in writing by holders of at least XXXXXXXXXX % of the votes represented by the Units entitled to vote on such resolution; "Stock Exchange" means the XXXXXXXXXX; "Subco New Third Party Debt" means the debt that Subco has incurred by borrowing from third party lenders in order, inter alia, to fund the purchase of the Units under the Offer. ... XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling

2006 Ruling 2006-0181061R3 - Butterfly Distribution - XXXXXXXXXX

In order to facilitate the proposed distribution described in Paragraph 24, DC will cause some or all of the real property described as XXXXXXXXXX to be severed in equal (XXXXXXXXXX %) interests. 17. ... DC will transfer its legal title (but not beneficial ownership) to the XXXXXXXXXX, a XXXXXXXXXX % severed interest in the XXXXXXXXXX, a XXXXXXXXXX% severed interest in the XXXXXXXXXX, a severed interest in XXXXXXXXXX (hereinafter referred to as the "Trusteed Real Property") to Bare Trusteeco. ...
Ruling

2010 Ruling 2009-0311941R3 - Amendment to a RSU and Employee Stock Option

(iv) Notwithstanding anything in the Plan to the contrary, for Tradable Options granted on or after XXXXXXXXXX, if a Canadian Participant's employment with all members of the Group is terminated by reason of death, disability or retirement (as approved by the Committee for Tradable Options granted on or after XXXXXXXXXX) prior to the end of the Option Period, the Tradable Option shall become XXXXXXXXXX % vested and non-forfeitable and shall expire on XXXXXXXXXX of the Option Period. (v) Notwithstanding anything in the Plan to the contrary, for Tradable Options granted on or after XXXXXXXXXX, if a Canadian Participant's employment with all members of the Group is terminated by reason of normal termination, and within XXXXXXXXXX days of such normal termination the Canadian Participant becomes disabled, the Tradable Options shall become XXXXXXXXXX % vested and non-forfeitable and shall expire on the last day of the Option Period. ...
Ruling

2017 Ruling 2016-0675881R3 - Paragraph 55(3)(a) Internal Reorganization

All of the issued and outstanding shares in the capital of Canco are held by Holdco 1, Holdco 2 and Holdco 3 as follows: Shareholder Number of shares Redemption amount Voting % XXXXX Class A $XXXXX per share XXXXX% Holdco 1 preferred (redemption amount) (one vote per XXXXX Class B $XXXXX per share share) preferred (redemption amount) Holdco 2 XXXXX common- XXXXX% (one vote per share) Holdco 3 XXXXX common- XXXXX% (one vote per share) 4. ... A, who hold the following number of shares: Shareholder Number of shares Redemption amount Voting % XXXXX common XXXXX% Mr. ...
Ruling

2008 Ruling 2007-0255401R3 - Swap Termination

At that time, the applicable foreign currency exchange rate was US$1 = CDN$XXXXXXXXXX and the Canadian dollar equivalent of US$XXXXXXXXXX was CDN$XXXXXXXXXX; and (b) On XXXXXXXXXX, XXXXXXXXXX Co issued further Public Notes having an aggregate Principal Amount of US$XXXXXXXXXX. At that time, the applicable foreign currency exchange rate was US$1 = CDN$XXXXXXXXXX and the Canadian dollar equivalent of US$XXXXXXXXXX was CDN$XXXXXXXXXX. 9. ...
Ruling

2006 Ruling 2005-0141921R3 - Public Company Spin-off

On XXXXXXXXXX, DC completed the sale of a XXXXXXXXXX% interest in the "XXXXXXXXXX " property located in the XXXXXXXXXX area to XXXXXXXXXX. for consideration consisting of XXXXXXXXXX common shares of XXXXXXXXXX. ... The fair market value, immediately before the transfer described in Paragraph 26 below, 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). ...

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