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Ruling
2006 Ruling 2005-0161681R3 - 88(1)(c) and (d)
("Holdco2 ") through one of its subsidiary wholly-owned corporations. 5. ...
Ruling
2006 Ruling 2005-0158461R3 - Single-wing butterfly - XXXXXXXXXX
Currently, there are XXXXXXXXXX Class A Shares and XXXXXXXXXX Common Shares of DC issued and outstanding, which are owned as follows: Shareholder Common Shares Class A Shares % of Votes Sibling1 XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Sibling2 XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Sibling3 XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Sibling4 XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX The shares of DC are held by each of the shareholders as capital property. ...
Ruling
2006 Ruling 2006-0177231R3 - convert from a closed-end to open-end unit trust
XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling
2006 Ruling 2006-0182431R3 - Purchase of a Target
Prior to its winding-up as described in Paragraph 22, CanSub, a wholly-owned subsidiary of Target, owned XXXXXXXXXX % of all of the issued and outstanding shares of the capital stock of Opco. ...
Ruling
2006 Ruling 2006-0191431R3 - merging of 3 identical family trusts
XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling
2006 Ruling 2006-0196691R3 - 18(9.1): Deductibility of a "Penalty".
. $ (i) The Term A Loan Facility XXXXXXXXXX (ii) The Term B Loan Facility XXXXXXXXXX (iii) The Parent Senior Notes XXXXXXXXXX (iv) The Parent Subordinated Senior Notes XXXXXXXXXX The U.S. dollar-Canadian dollar exchange rate at the issuance of the above US Debts was US$1 equals CA$1.3292. 9. ...
Ruling
2006 Ruling 2006-0192521R3 - Loss Utilization
Holdco holds XXXXXXXXXX % of the issued and outstanding common shares of Profitco XXXXXXXXXX. ...
Ruling
2007 Ruling 2006-0206431R3 - Partnership Reorganization
The Partnership owns XXXXXXXXXX % of the shares of XXXXXXXXXX. 14. All of the Partners are residents of Canada. ...
Ruling
2005 Ruling 2004-0093711R3 - Incorporating a Proprietorship
2005 Ruling 2004-0093711R3- Incorporating a Proprietorship Unedited CRA Tags 125(7) 56(2) & (4) Principal Issues: Whether a physician who is also a faculty member of a university can conduct a medical practice through a corporation. ...
Ruling
2005 Ruling 2004-0055911R3 - Withholding tax on interest; Part XIII
Position: Yes / yes Reasons: XXXXXXXXXX- 1. "Obligation" is a broad term 2. ...