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All of the issued and outstanding common shares of CCo are owned by Parentco (XXXXXXXXXX %), ACo (XXXXXXXXXX %) and BCo (XXXXXXXXXX %). ... Loan1 has a term of XXXXXXXXXX and bears interest at a rate of XXXXXXXXXX %. ... Yours truly, XXXXXXXXXX For Director International & Trusts Division Income Tax Rulings Directorate ...

En effet, le XXXXXXXXXX, Opérante a acheté un fonds de terre à XXXXXXXXXX, pour un montant de XXXXXXXXXX $, plus les coûts accessoires, pour un coût total à l’achat de XXXXXXXXXX $. 7. Lors de l’acquisition du fonds de terre, Opérante a payé un montant comptant de XXXXXXXXXX $ et a assumé une balance de prix de vente de XXXXXXXXXX $, échéant le XXXXXXXXXX. ... En date du XXXXXXXXXX, le Coût du fonds de terre était de 5 029 036 $ et la juste valeur marchande d’environ XXXXXXXXXX $. 13. ...

The issued and outstanding capital of Opco is detailed in the following schedule: Shareholder Number Class Aggregate Redemption Amount Aggregate ACB Aggregate PUC XXXXXXXX ("Child1") XXXXXXX Common Shares $ XXXXXXXX $ XXXXXXXXXX XXXXXXXX ("Child2") XXXXXXX Common Shares $ XXXXXXXX $ XXXXXXXXXX XXXXXXXX ("Child3") XXXXXXX Common Shares $ XXXXXXXX $ XXXXXXXXXX XXXXXXXX ("Father") XXXXXXX Class A Preferred Shares $XXXXXXXX $XXXXXXX $XXXXXXXXX XXXXXXXX ("Mother") XXXXXXX Class A Preferred Shares $XXXXXXXX $XXXXXXX $XXXXXXXXX Each of the Opco Common Shares and the Opco Class A Preferred Shares is entitled to one vote. ... Father will incorporate three new corporations (" Holdco1", "Holdco2" and "Holdco3") under the provisions of the BCA (Holdo1, 2 and 3 are collectively referred to hereafter as "Holdcos", and individually as "Holdco"). ... On the day following the redemption of the Second Class Preferred Shares of Holdco1, 2 and 3 as described in paragraph 19 above, Opco will purchase for cancellation the following Common Shares and redeem the following Class A Preferred Shares: (a) XXXXXXXXXX of its Common Shares and XXXXXXXXXX of its Class A Preferred Shares from Holdco1; (b) XXXXXXXXXX of its Common Shares and XXXXXXXXXX of its Class A Preferred Shares from Holdco2; and (c) XXXXXXXXXX of its Common Shares and XXXXXXXXXX of its Class A Preferred Shares from Holdco3, for an amount, in each case, equal to their FMV, and will issue to each of Holdco1, Holdco2 and Holdco3 in consideration therefor a demand non-interest bearing promissory note with a principal amount and FMV equal to that amount (in the case of Holdco1, the " Opco Redemption Note1"; in the case of Holdco2, the "Opco Redemption Note2"and in the case of Holdco3, the "Opco Redemption Note3"). ...

Opco will transfer the following properties to Newco1: • All of the Newco5 Common Shares • All of the Newco6 Common Shares • All of the Newco11 Common Shares • Right to receive XXXXXXXXXX of Opco’s dividend refund in respect of the taxation year that includes the day of the redemptions of the Opco Class B Shares described in Paragraphs 174, 175, and 176 • Cash for a purchase price equal to the aggregate fair market value of the properties so transferred. ... Opco will transfer the following properties to Newco2: • All of the Newco7 Common Shares • All of the Newco8 Common Shares • All of the Newco12 Common Shares • Right to receive XXXXXXXXXX of Opco’s dividend refund in respect of the taxation year that includes the day of the redemptions of the Opco Class B Shares described in Paragraphs 174, 175, and 176 • Cash for a purchase price equal to the aggregate fair market value of the properties so transferred. ... Opco will transfer the following properties to Newco3: • All of the Newco9 Common Shares • All of the Newco10 Common Shares • All of the Newco13 Common Shares • Right to receive XXXXXXXXXX of Opco’s dividend refund in respect of the taxation year that includes the day of the redemptions of the Opco Class B Shares described in Paragraphs 174, 175, and 176 • Cash for a purchase price equal to the aggregate fair market value of the properties so transferred. ...

Chassé: 21(1)(b) The following documents are enclosed: 21(1)(b) 2)     The original of the Ministerial Order and the submission in English and French signed by the Minister of National Revenue. 3)     Five copies of the approved Regulatory Impact Analysis Statement, in English and French. 4)     A completed Request for Insertion in the Canada Gazette. ...

2009 Ruling 2008-0284551R3- Royalty Paid to Non-Resident Unedited CRA Tags 212(1)(d); 245; Article XII & XXIX-A of Canada-U.S. ... Opco owns XXXXXXXXXX % of each of Opco2 and Opco 3, XXXXXXXXXX % of Opco1 and XXXXXXXXXX % of Opco4). ... Yours truly, XXXXXXXXXX For Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ENDNOTES 1 XXXXXXXXXX ...

Principal Issues: Request for amendments to the facts and the proposed transactions as well as a minor revision to an advance income tax ruling in respect of advance ruling # 2001-009054 (the "Ruling"). ... Reasons FOR POSITION TAKEN: N/A XXXXXXXXXX 2002-011649 XXXXXXXXXX, 2002 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Ruling # 2001-009054 (the "Ruling") This is in reply to your e-mail dated XXXXXXXXXX in which you requested amendments to the Ruling issued to the above-referenced taxpayers on XXXXXXXXXX, 2001. ... Paragraph 16, subparagraph 2, delete the 1st sentence and insert the following in its place: On incorporation, Canco # 2 XXXXXXXXXX, will subscribe for and Newco will issue to Canco # 2 or the said corporation controlled directly or indirectly XXXXXXXXXX common shares for aggregate consideration of $XXXXXXXXXX. 4. ...

This provision allows amounts paid "... for reasonable expenses relating to the modification of a dwelling... " to be deducted as a medical expense for certain patients.  You mention in your letter that the use of the word "modification" seems to imply that while the expense of modifying an existing dwelling may be eligible to qualify as a medical expense, the same or similar expense incurred in the construction of a new dwelling would not qualify. ...

This increase will be affected in several tranches and all the other facts and proposed transactions with respect to Structure # 1 will be the same as indicated in the Original Ruling. Structure # 2 as described in paragraphs 34 to 38 of the Original Ruling will be unwound as described no later than XXXXXXXXXX. However, Structure # 2 will not be repeated in 2012; as a result, paragraph 39 of the Original Ruling is being omitted as it will no longer be required. ...

Norco1 currently owns approximately XXXXXXXXXX % of the common equity of Pubco. ... Pubco directly owns XXXXXXXXXX % of the equity interest in Forco1 and the remaining XXXXXXXXXX % is owned by Cansub, which is XXXXXXXXXX % owned by Pubco. ... Currently, all of the common shares in Opco are owned by Forco2, (as to approximately XXXXXXXXXX %), Holdco3 (as to approximately XXXXXXXXXX %), and Stateco (as to approximately XXXXXXXXXX %). ...