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(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. ...

As such, F’s deemed proceeds of disposition were $XXXXXXXXXX, pursuant to subparagraph 70(6)(b)(ii), resulting in $ XXXXXXXXXX capital gain for F’s XXXXXXXXXX taxation year. ...

XXXXXXXXXX 2020-086244 XXXXXXXXXX Dear XXXXXXXXXX: Re: CONTAINS TAXPAYER INFORMATION Advance Income Tax Ruling – Subsection 84(2) and Charitable donation XXXXXXXXXX This is in reply to your letter dated XXXXXXXXXX in which you requested an advance income tax ruling (“Ruling”) on behalf of the above-named taxpayers. ...

XXXXXXXXXX 2021-088901 XXXXXXXXXX, 2021 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request – Redemption of Mutual Fund Trust Units Held by Registered Plans XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX requesting an advance income tax ruling (“Ruling”) on behalf of the above-named Taxpayer. ...

The number and classes of such shares and their FMV immediately before the Deceased’s death were as follows: Type of shares Class # of shares FMV Common Class 1 XXXXXXXXXX XXXXXXXXXX Common Class 2 XXXXXXXXXX XXXXXXXXXX Special Class A XXXXXXXXXX XXXXXXXXXX Special Class B XXXXXXXXXX XXXXXXXXXX Special Class C XXXXXXXXXX XXXXXXXXXX 6. ...

Step 9 – there is no non-resident vendor and the purchaser is Taxpayer 6 for the acquisition of all issued and outstanding common shares of Taxpayer 11. 21. ...

The tax attributes attached to the shares of Opco immediately before the Deceased’s death were as follows: Shareholder Number & Class of FMV ACB PUC Shares of Opco Deceased XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Deceased XXXXX Opco Class E Special Shares XXXXX XXXXXX XXXXX Deceased XXXXX Opco Class F Special Shares XXXXX XXXXXX XXXXX Deceased XXXXX Opco Class Z Special Shares XXXXX XXXXXX XXXXX Child 1 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Child 2 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Child 5 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Child 6 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Child 7 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX 7. ...

XXXXXXXXXX 9.The XXXXXXXXXX units of XXXXXXXXXX are owned by over XXXXXXXXXX individuals and corporations that deal at arm's length with XXXXXXXXXX. 10.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.XXXXXXXXXX is a taxable Canadian corporation and a public corporation whose shares are listed for trading on the XXXXXXXXXX exchange. ...