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If death occurs during the first policy year, the amount payable is limited to the return of premiums paid plus interest at XXXXXXXXXX % per year to the date of death; the Policy may be surrendered at any time for its cash value, as calculated pursuant to the terms of the Policy; the cash value can be converted to an annuity by the owner of the Policy at any time under the terms and conditions set out in the Policy; the owner of the Policy is entitled to use the Policy as sole security for a policy loan, subject to the terms of the Insurer; the owner of the Policy has the right to change the name of the Beneficiary at any time during the Taxpayer's lifetime; and the owner of the Policy may assign the Policy. ... Yours truly, XXXXXXXXXX for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

The principal features are that the principal is repayable in US dollars and the outstanding principal bears interest at XXXXXXXXXX % per annum. 6. ... The principal features are that (i) the obligations are not secured, (ii) the principal is repayable in US dollars, (iii) for those issued on XXXXXXXXXX, the outstanding principal bears interest at XXXXXXXXXX % per annum, and (iv) for those issued on or after XXXXXXXXXX, the outstanding principal does not bear interest. ...

The Taxpayer's assets include, inter alia: i) interest free loans made by the Taxpayer to one or more of its wholly-owned subsidiaries, where such loans were made for the purpose described in paragraph 25 of Interpretation Bulletin IT-533- i.e, to enhance the Taxpayer's income-earning capacity from its other business or property (other than property the income from which is exempt or an interest in a life insurance policy); and ii) Intercompany Balances, which could be said to not be used for income producing purposes, the total of which, on XXXXXXXXXX, was less than $XXXXXXXXXX (approximately XXXXXXXXXX % of the Taxpayer's total assets on XXXXXXXXXX). At the time of the proposed transactions, the total amount of the Intercompany Balances will be less than XXXXXXXXXX % of the Taxpayer's total assets. 10. ...

Le principal actif de Fiducie A est un intérêt de XXXXXXXXXX % dans Société de personnes. 6. L'acquisition de l'intérêt dans Société de personnes par Fiducie A a été financée en grande partie par une avance de XXXXXXXXXX $ de Société C à Fiducie A. ...

Canco will be a wholly-owned subsidiary of Asub 2; viii) XXXXXXXXXX % of the issued Topco Class A Shares will be held by Canco; ix) Asub 2 will be a wholly-owned XXXXXXXXXX subsidiary of Asub 1 and will be a non-resident of Canada; x) Asub 2 and Canco will enter into a partnership agreement to form XXXXXXXXXX, a general partnership (the "Partnership"). Pursuant to the terms of such partnership agreement, Canco will have a XXXXXXXXXX% partnership interest, with the remaining XXXXXXXXXX% held by Asub 2; xi) XXXXXXXXXX % of the issued Topco Class B Shares will he held by the Partnership and, xii) Acquireco, Holdco, Topco and Canco will be private corporations. ...

(2) Is withholding tax at XXXXXXXXXX % applicable on benefit? (3) Do the transactions constitute a series of loans and repayments? ... Note A bears interest at XXXXXXXXXX % per annum and matures in approximately XXXXXXXXXX years. ...

Insurer has offered the Policy to the Taxpayer with following terms: the Taxpayer will pay a single premium of $XXXXXXXXXX for the Policy; the Insurer will pay a $XXXXXXXXXX death benefit to the Beneficiary upon the death of the Taxpayer less any amount of indebtedness owing under the Policy and subject to any assignment of that benefit made by the Taxpayer and subject to the other terms set out in the Policy; the Policy will bear an accumulated face amount that will include the amount paid for the Policy and the amounts added to that amount each year at the discretion of the Insurer; the accumulated face amount of the Policy can be converted to an annuity by the Taxpayer at any time under the terms and conditions set out in the Policy; as the certificate owner named under the Policy, the Taxpayer is entitled to obtain a loan from the Insurer at a rate of XXXXXXXXXX % under the conditions specified in the Policy and using the Policy as security for the loan; the Policy is revocable; Taxpayer has the right to change the name of the Beneficiary at any time; and other terms and conditions specified in the Policy that are not relevant to this ruling. 3. ... XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

2005 Ruling 2005-0147131R3- Continuance from XXXXXXXXXX to XXXXXXXXXX Unedited CRA Tags Subdivision i Principal Issues: Whether the continuance of a corporation from XXXXXXXXXX to XXXXXXXXXX is a disposition of the shares or the underlying assets & liabilities. ... Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

All of the issued and outstanding shares of XXXXXXXXXX Canadian Advisor are owned by a wholly owned subsidiary of a corporation that is owned XXXXXXXXXX% by Manager and XXXXXXXXXX % by a company that is a sister company to the Manager. ... Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

The incorporating documents provide that when the "interest-holders" convene to decide on certain issues (such as changes to the by-laws, change of name, dissolution of the LLC or increase in capital contributions), notwithstanding that the "interests" entitle Foreignco B to XXXXXXXXXX% of the votes and the Non-resident to XXXXXXXXXX % of the votes, unanimous consent by both "interest-holders" is required in respect of such decisions. ... Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...