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Section 18.1 would not apply, if before the end of the taxation year in which the XXXXXXXXXX expenditures are made, income in respect of the XXXXXXXXXX exceeding XXXXXXXXXX % of such XXXXXXXXXX expenses is included in computing the XXXXXXXXXX Partnership's income for that year. 3. ... Under cover of your letter of XXXXXXXXXX, you provided us with copies of the following draft documents in support of your ruling request: * XXXXXXXXXX PURPOSE OF THE PROPOSED TRANSACTIONS The purpose of the proposed transactions is to XXXXXXXXXX. ...

Definitions Non-Statutory Terms In this letter unless otherwise expressly stated: (a) "XXXXXXXXXX" means XXXXXXXXXX, a corporation incorporated under the CBCA by certificate of incorporation dated XXXXXXXXXX, all of the issued and outstanding shares of which are owned by XXXXXXXXXX; (b) "XXXXXXXXXX" means XXXXXXXXXX, a corporation incorporated under the Canada Corporations Act by letters patent dated XXXXXXXXXX and continued under the CBCA by certificate of continuance dated XXXXXXXXXX, as amended by certificates of amendment dated XXXXXXXXXX, of which XXXXXXXXXX % of its issued and outstanding shares are owned individually by XXXXXXXXXX as to 33 1/3% each; (c) "XXXXXXXXXX" means XXXXXXXXXX, a corporation incorporated under the CBCA by certificate of incorporation dated XXXXXXXXXX, all of the issued and outstanding shares of which are owned by XXXXXXXXXX; and (d) "XXXXXXXXXX" means XXXXXXXXXX, a corporation incorporated under the CBCA by certificate of incorporation dated XXXXXXXXXX, all of the issued and outstanding shares of which are owned by XXXXXXXXXX. ... The authorized share capital of each of XXXXXXXXXX includes the following classes of shares: (a) an unlimited number of voting, fully participating common shares (the "class A common shares"); and (b) an unlimited number of voting, redeemable and retractable preferred shares with a non-cumulative monthly dividend of XXXXXXXXXX % (the "class C preferred shares"). 9. ...

This aspect of the ruling is similar to that which we ruled favourably on in file # 993252, dated XXXXXXXXXX, 2000. ... Pursuant to the partnership agreement of the XXXXXXXXXX Partnership, XXXXXXXXXX% of the profits and losses of the XXXXXXXXXX Partnership, and XXXXXXXXXX % of the capital of the XXXXXXXXXX Partnership in the event of dissolution, will be allocated to its limited partners on a pro rata basis. ...

XXXXXXXXXX is a taxable Canadian corporation and was incorporated on XXXXXXXXXX directly owns shares representing approximately XXXXXXXXXX % of the voting rights of XXXXXXXXXX and therefore controls XXXXXXXXXX. ... Following the transfer described herein, the PUC and ACB of the XXXXXXXXXX common shares held by XXXXXXXXXX was as follows: Description # of Common Shares ACB PUC XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX subsequently converted the XXXXXXXXXX Preferred Shares into XXXXXXXXXX Shares of XXXXXXXXXX in accordance with the conversion privileges attached to the XXXXXXXXXX Preferred Shares. ...

Reasons: (1) Ruling granted previously in similar circumstances- transaction not to confer benefit – in particular, transaction at less than FMV permitted tax deferred transaction with restriction of ACB of FA1 shares to amount transferred for. (2) The transactions are not a misuse or abuse of the Act or its provisions. There is no avoidance of income tax achieved, only a deferral – not clear that policy of Act intended to deny deferral in these circumstances. ...

2020 Ruling 2020-0865971R3- Loss consolidation arrangement Unedited CRA Tags 20(1)(c), 55(2) * Principal Issues: Whether the LCA is acceptable Position: Yes Reasons: The proposed transactions fall within CRA's policy position XXXXXXXXXX 2020-086597 XXXXXXXXXX, 2020 Dear XXXXXXXXXX: Subject: Advance Income Tax Ruling XXXXXXXXXX We are writing in response to your letter of XXXXXXXXXX and revised letter of XXXXXXXXXX wherein you requested an advance income tax ruling on behalf of the above-referenced taxpayers. ... Opco will use the proceeds of the Daylight Loan to make a loan of the same amount, $XXXXXXXXXX, bearing interest at the estimated rate of XXXXXXXXXX % per annum to Lossco (the "Lossco Loan"). ...

In May 2014, the NEB issued the MH-001-2013 Reasons for Decisions – Set-aside and collection mechanisms (Pipeline Abandonment- Financial Issues) (the “SAM/COM Decision”), which required certain NEB-regulated pipeline companies to have a set-aside mechanism in place by January 1, 2015, and to begin accumulating funds to pay for pipeline reclamation. 4. ... Yours truly, XXXXXXXXXX Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

In May 2014, the NEB issued the MH-001-2013 Reasons for Decisions – Set-aside and collection mechanisms (Pipeline Abandonment- Financial Issues) (the “SAM/COM Decision”), which required certain NEB-regulated pipeline companies to have a set-aside mechanism in place by January 1, 2015, and to begin accumulating funds to pay for pipeline reclamation. 4. ... Yours truly, XXXXXXXXXX Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

In May 2014, the NEB issued the MH-001-2013 Reasons for Decisions – Set-aside and collection mechanisms (Pipeline Abandonment- Financial Issues) (the “SAM/COM Decision”), which required certain NEB-regulated pipeline companies to have a set-aside mechanism in place by January 1, 2015, and to begin accumulating funds to pay for pipeline reclamation. 7. ... Yours truly, XXXXXXXXXX Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

In May 2014, the NEB issued the MH-001-2013 Reasons for Decisions – Set-aside and collection mechanisms (Pipeline Abandonment- Financial Issues) (the “SAM/COM Decision”), which required certain NEB-regulated pipeline companies to have a set-aside mechanism in place by January 1, 2015, and to begin accumulating funds to pay for pipeline reclamation. 4. ... Yours truly, XXXXXXXXXX Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...