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Technical Interpretation - External summary

4 January 2022 External T.I. 2015-0607531E5 F - Action admissible de petite entreprise -- summary under Paragraph (e)

X, CRA indicated that Amalco shares that were substituted for his Holdco common shares had not been held by anyone other than him, and that, prior to being replaced by Holdco shares, the original Opco share had not been owned by anyone other than him and in this regard, stated that s. “110.6(1)(e) can apply respecting multiple substitutions.” ...
Conference summary

10 October 2024 APFF Financial Strategies and Instruments Roundtable Q. 7, 2024-1024211C6 F - CELIAPP et transfert via la succession -- summary under Paragraph 146.6(15)(a)

. In order to be eligible for a joint designation, amounts must be distributed from the FHSA to the estate before the deceased holder's FHSA ceases to be a FHSA, generally before the end of the year following the year of the holder's death, unless the FHSA ceased to be a FHSA at an earlier date under subsection 146.6(16). ...
Ruling summary

2012 Ruling 2012-0452291R3 - XXXXXXXXXX - ATR -- summary under Subsection 17(2)

Pubco (acting through a branch in Country 1 assumed here to be Luxembourg) will subscribe with cash for common shares and/or mandatorily redeemable preferred shares ("MRPS") of Finco. ...
Ruling summary

2013 Ruling 2013-0491651R3 - Cross-Border Butterfly -- summary under Distribution

In determining the net FMV of each type of property of DC and its subsidiaries (anticipated to be cash or near-cash property and business property), (a) the net FMV of any accounts receivable, trade receivables, inventories and prepaid expenses of such corporation or partnership remaining after the allocation of current liabilities to cash or near-cash property will be reclassified as business property "to the extent that such property will be collected, sold, used or consumed in the ordinary course of business to which such property relates," and (b) any current ("as determined by the method prescribed by the applicable pension legislation") pension plan, post-retirement benefit or liability insurance liabilities of DC will be allocated to cash or near-cash property, and any such liabilities of a non-current nature will be allocated to business property and similarly for employee incentive plans. ...
Ruling summary

2014 Ruling 2014-0533601R3 - Spin-off butterfly - subsection 55(2) -- summary under Distribution

Proposed transactions The following transactions will occur under a Plan of Arrangement to accomplish a spin-off of Subco 1 and 2 Transferred Business through Spinco, which was incorporated but has no shareholders: Under a s. 86 reorganization, each DC shareholder will exchange all of its DC common shares for "DC Butterfly Shares" and Class D, E or F common shares (with the aggregate paid-up capital of the exchanged shares being apportioned), such that the aggregate fair market value of the DC Butterfly Shares will be equal to the "Butterfly Ratio" (equal to the relative net FMV of Subco 1 Transferred Business 1 and 2) multiplied by the aggregate FMV of all the DC shares held immediately before the exchange and the FMV of the Class D, E or F common shares received on the exchange will capture the balance of the FMV of the exchanged Class A, B or C common shares. ...
Technical Interpretation - Internal summary

8 January 2016 Internal T.I. 2015-0604491I7 - mandatory redeemable preferred shares -- summary under Share

. These corporate documents are not bilateral contracts…. Shares may or may not carry votes, but in respect of the governance of the corporation, typically only shareholders may vote on matters such as the election of the board of directors. ...
Ruling summary

2015 Ruling 2015-0604051R3 - Internal Reorganization -- summary under Subparagraph 55(3)(a)(iii)

Rulings The s. 55(3)(a) exception will apply to the dividends in 1, 3 and 7, provided there is not a disposition of property or an increase in interest described in ss. 55(3)(a)(i) to (v) which is part of the series of transactions or events and the proposed transactions, by themselves, will not be considered to result in any disposition to, or increase in interest by, an unrelated person described in ss. 55(3)(a)(i) to (v). ...
Technical Interpretation - External summary

5 August 2022 External T.I. 2021-0877051E5 F - TOSI and excluded amount -- summary under Related Business

(a)(ii) of that definition, that prima facie, the mere fact of M-1 and C-1 acting as directors of Investco would not be sufficient in itself to consider that they were actively involved, on a regular basis, in the activities of Investco's business,” but that the “ownership test” in s. ...
Ruling summary

2021 Ruling 2021-0911211R3 - Foreign Takeover -- summary under Adjusted Cost Base

By virtue of the First Merger, each common and preferred share of Target was converted into the right to receive the applicable “Merger Consideration,” being the “Share Consideration” (being common shares to be issued by XXXXXXXXXX being the direct (apparently Canadian-resident) parent of Opco referred to herein as Parent) and the “Cash Consideration.” ...
Ruling summary

2023 Ruling 2022-0957491R3 F - Butterfly Reorganization -- summary under Distribution

Transferor will transfer a pro rata portion of its two types of property to Child 1 Holdco and Child 2 Holdco on a s. 85(1) rollover basis in consideration in each case for preferred shares of the respective Holdco and the assumption of ½ of the Estate Note and Trust Note, so that the two notes will be extinguished by operation of law. ...

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