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The common shares held by each TC have a FMV of XXXXXXXXXX % or more of the FMV of all the issued and outstanding common shares of DC. ... The ACB of the issued and outstanding shares in the capital of DC is as follows: Shareholder Class of Shares ACB TC1 XXXXXXXXXX Shares $ XXXXXXXXXX common shares $ XXXXXXXXXX TC2 XXXXXXXXXX Shares $XXXXXXXXXX common shares $XXXXXXXXXX TC3 XXXXXXXXXX Shares $XXXXXXXXXX XXXXXXXXXX Shares $XXXXXXXXXX common shares $ XXXXXXXXXX 15. ... Accordingly, DC will own XXXXXXXXXX % of the voting shares of each TC and these shares will have a FMV that is more than 10% of the FMV of all the issued and outstanding shares of the particular TC. 38. ...

Yours truly, XXXXXXXXXX Manager, International Section I International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Paragraph 18 of the Ruling is amended as follows: The words "... the later of XXXXXXXXXX and... ...

April 14, 2004 HEADQUARTERS HEADQUARTERS Appeals Branch Income Tax Rulings CPP / EI Appeals Division Directorate 14th floor C. ...

11 September 1989 Ruling I3241 F- Transitional Rules for CCA Class 10(w) Unedited CRA Tags n/a   September 11, 1989 Mr. ...

30 October 1989 Ruling 8265002 F- Remission of Income Tax Unedited CRA Tags n/a Minister's Office (2) 8265002 Central Records 8025021 File Copy Return to Technical Interpretations 3rd Floor, Fuller Building   October 30, 1989 19(1) I am responding to your request for remission of income tax under the Financial Administration Act in respect of your 1984 taxation year. ...

For purposes of determining the amount of any deemed dividend under the provisions of subsection 84(2) of the Act, is this liability deducted in the determination of "... the amount or value of the funds or property distributed or appropriated... ...

18 June 1992 Ruling 9217811 F- Qualified Investments For Rrsp Nikkei Index Call Option Unedited CRA Tags ITR 4900(1)(e)   June 18, 1992 Analysis Put (Put Option) An option to sell a specified commodity at a specified price and time.  ...

Between XXXXXXXXXX, Bidco acquired approximately XXXXXXXXXX % of the outstanding common shares of Canco 1 from the shareholders of Canco 1. 16. ... (Foreign Co 1 continued to hold the remaining XXXXXXXXXX % of the Bidco common shares.) 19. ... Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

X owns XXXXXXXXXX common shares (XXXXXXXXXX %) and a group of employees of Amalco and its affiliates, together, owns XXXXXXXXXX common shares (XXXXXXXXXX %). ... The New Debenture Loan matures XXXXXXXXXX years after its issuance and bears interest at XXXXXXXXXX %. ... Simple interest will accrue on the Lossco Loan and will be calculated at a rate of XXXXXXXXXX %. ...