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Example 2 Parent $45000 45% Active business assets 44000 44 Shares of subsidiary 1 11000 11 Investments $100000 100% Subsidiary: Active business assets  $31000 59% Shares of subsidiary 2 14000 29 Investments 6000 12   51000 100% In your view, the parent company would meet the test in paragraph 110.6(1)(c)(iii) of the Act because more than 50% of the fair market value of the assets are used in combination of active business assets and shares of a subsidiary (meet the holding period test and the 50% test).  ...

Under 13(27)(c) & (28)(d) a t/p is considered to have acquired property immediately before disposition if none of the other times occur earlier. ...

8 November 1991 Ruling 912013 F- Employee Shares Purchase Plan Unedited CRA Tags 15(1)(c), 15(1), 47(1), 54 adjusted cost base   Dear Sirs: Re: Employee Shares Purchase Plan We refer to your letter of July 18, l991 to our Charlottetown District Office, which was forwarded to this office for a response. ...

The attributes of the issued and outstanding shares of Holdco are as follows: Class A: 1 vote per share; redeemable @ $XXXXXXXXXX per share; and no dividend entitlement. Class B: non-voting; redeemable and retractable @ $XXXXXXXXXX per share; and no dividend entitlement. Class C: non-voting; redeemable and retractable @ $XXXXXXXXXX per share; and no dividend entitlement. ...

The Trust Notes bear interest at a rate of XXXXXXXXXX % per annum, with interest payable the last business day of each month, and they mature on XXXXXXXXXX. ... The Trust is a limited partner of the Partnership and owns approximately XXXXXXXXXX % as of XXXXXXXXXX, of the issued and outstanding LP Units. ... Yours truly, XXXXXXXXXX Section Manager For Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

In accordance with the relevant terms of the REIT Declaration of Trust and paragraphs 108(2)(b) and 132(6)(b) and subsection 132(7) of the Act, the REIT qualifies as a mutual fund trust and, specifically, the REIT: (1) limits its undertaking to the investing of its funds in property, and to acquiring, holding, maintaining, improving, leasing and managing real property and interests in real property that is capital property; (2) invests more than XXXXXXXXXX % of its property in Permitted Investments; (3) earns more than XXXXXXXXXX% of its income- computed without regard to subsection 104(6) of the Act- from Permitted Investments; (4) does not invest any more than XXXXXXXXXX% of its property in any combination of bonds, securities or shares in the capital stock of any one corporation or debtor; and (5) is not maintained primarily for the benefit of non-resident persons, and non-residents of Canada are collectively beneficial owners of less than XXXXXXXXXX% of the REIT Units. 5. ... XXXXXXXXXX GP owns a XXXXXXXXXX % general partnership interest and XXXXXXXXXX LP Inc. owns a XXXXXXXXXX% limited partnership interest. ... Yours truly, XXXXXXXXXX Section Manager For Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

The amount to be added to the stated capital of the Newco4 Class A Common Shares so issued will be an amount equal to the aggregate adjusted cost base of the common shares of Pubco so transferred (the "Transferred Shares "4 ""). The amount to be added to the stated capital of the Newco5 Class A Common Shares so issued will be an amount equal to the aggregate adjusted cost base of the common shares of Pubco so transferred (the "Transferred Shares "5 ""). The amount to be added to the stated capital of the Newco6 Class A Common Shares so issued will be an amount equal to the aggregate adjusted cost base of the common shares of Pubco so transferred (the "Transferred Shares "6 ""). 15. ...

Le PBR et le CV des XXXXXXXXXX actions de catégorie "XXXXXXXXXX" du capital-actions de IMMEUBLECO possédées par GESTCOY est de XXXXXXXXXX $. 6. ... Aucun dividende, au cours d'un mois donné, ne peut être payé à l'égard des actions de catégorie XXXXXXXXXX à moins que le dividende prévu pour les actions de catégorie "XXXXXXXXX " n'ait été déclaré et payé ou qu'une provision suffisante n'ait été faite pour son paiement. ... La JVM et la valeur de rachat des XXXXXXXXXX actions de catégorie "XXXXXXXXXX " du capital-actions de NOUCO qui seront émises à M. ...

DC holds less than 10 % of the issued and outstanding share capital of Pubco, as such DC is not able to exercise any degree of significant influence over Pubco. ... For greater certainty, the Transferee Corporation preference shares issued to DCAmalco as described herein will: (g) represent greater than 10 % of the issued share capital (having full voting rights under all circumstances) of Transferee Corporation, having a fair market value of more than 10 % of the fair market value of all the issued shares of the capital stock of the Transferee Corporation; and (h) not be sufficient to cause an acquisition of control of Transferee Corporation by DCAmalco. 15. ... DCAmalco will purchase for cancellation from Transferee Corporation all of its DCAmalco common shares for an amount equal to their fair market value ("purchase price"), and will issue to Transferee Corporation in consideration therefor a demand non-interest bearing promissory note with a principal amount and fair market value equal to the purchase price of the DCAmalco common shares held by Transferee Corporation ("the DCAmalco Redemption Note "). ...

XXXXXXXXXX 2023-096168 XXXXXXXXXX, 2023 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request – Underground Mine XXXXXXXXXX We are writing in response to your request for an advance income tax ruling, dated XXXXXXXXXX on behalf of the above-noted Taxpayers. ... Core logging – geological and geotechnical data collection from XXXXXXXXXX drill core. ... Resource modelling – taking the orebody knowledge and understanding of controls to mineralization gained during geological modelling and using these to build a block model. ...