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Yours truly, XXXXXXXXXX for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

As a result of the above change we confirm that subparagraphs 22(i) and (ii) of the Ruling are cancelled and replaced as follows: (i) the Family B Properties; (ii) a XXXXXXXXXX % beneficial undivided interest in the Co-Tenancy Properties and the XXXXXXXXXX Properties; Notwithstanding the above noted amendments to the proposed transactions, we confirm that, subject to the conditions set out therein, the rulings given in the Ruling will continue to be binding on the Canada Customs and Revenue Agency ("CCRA") in accordance with the practice outlined in Information Circular 70-6R3, dated December 30, 1996, provided that all the proposed transactions are completed in the manner otherwise described in the Ruling, as amended herein, before XXXXXXXXXX. ...

In return for these contributions, XXXXXXXXXX will receive a XXXXXXXXXX % interest in the profits and losses of the Partnership, respectively. ...

Reasons: Consistent with previous ruling and opinion # 9706043, 9506285. ...

XXXXXXXXXX 2018-078494 XXXXXXXXXX, 2018 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request – supplement to file 2015-056473 XXXXXXXXXX We are writing in response to your letter of XXXXXXXXXX wherein you advised us of a certain change to the additional information in the Advance Income Tax Ruling dated XXXXXXXXXX (2015-056473) subsequently modified by the letter issued by the Canada Revenue Agency (“CRA”) on XXXXXXXXXX (2015-062209) (referred collectively as the “Original Ruling”), and subsequently modified by the letter issued by the CRA on XXXXXXXXXX (2018-076504) (the “Supplemental Ruling” and, together with the Original Ruling, referred collectively as the “XXXXXXXXXX”) on behalf of the above-referenced taxpayers. ...

16 October 1992 Ruling 9228451 F- Leasehold Improvements and the Available for Use Rules Unedited CRA Tags 13(27), 13(28), ITR 1102(5), Class 13   Officer: Jean-Pierre Simard October 16, 1992 NOTES TO FILE LEASEHOLD IMPROVEMENTS AND THE "AVAILABLE FOR USE" RULES Subsections 13(27) and 13(28) contain definitions of "available for use" for the purpose of the restriction on deduction contained in subsection 13(26). ...

Powrie     Memorandum August 31, 1992 Re: Cross-border butterfly involving real estate assets Facts The taxpayer (the "Particular Corporation") is a wholly-owned subsidiary of a U.S. ...

Yours truly, for DirectorFinancial Industries Division Rulings DirectorateLegislative & Intergovernmental Affairs Branch ...

8 September 1989 Ruling 89M09531 F- Addendum to Briefing Memorandum Unedited CRA Tags n/a   September 8, 1989 Carole Gouin-Toussaint John Shaw Director Bilingual Services and Resource Industries Division Subject: 24(1) Addendum to briefing memorandum Further to our discussion in the morning of August 29, 1989, we thought, given the emphasis which 19(1)   the representative of the above-captioned corporation, placed on our unwillingness to meet with him that we should outline what our position was, and is, on such meetings, and to illustrate that both 19(1)   and the District Office (D.O.) clearly understood the circumstances under which we would meet with him, but did not act upon that knowledge. ...

Pubco has direct ownership in the following subsidiary corporations in the following percentages: Subco (XXXXXXXXXX %) XXXXXXXXXX XXXXXXXXXX (This subsidiary provides services to other companies in the group.) ... On XXXXXXXXXX, Subco entered into a share purchase agreement with Pubco pursuant to which it purchased, from Pubco, XXXXXXXXXX shares in the capital of XXXXXXXXXX, representing XXXXXXXXXX % of the issued and outstanding shares of XXXXXXXXXX in consideration for the issuance of the Subco Shares. ... It is expected that XXXXXXXXXX will acquire XXXXXXXXXX % of Pubco’s interest in XXXXXXXXXX PURPOSE OF THE PROPOSED TRANSACTION 19. ...