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Yours truly, Randy Hewlett Director International Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

Moore for Director Partnerships & Corporate Financing Section International Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Your view is that upon the declaration of the dividend by NRCo a "debtor – creditor" relationship arises between NRCo and the shareholder and as a result, in Scenario 1, the amount paid by NRCo to the shareholder after the Immigration Day should not be considered a dividend, but should rather be considered a payment to discharge the debt claim arising as a result of the declaration of the dividend. ...

.), as amended to the date of this letter; (c) "Canadian development expense" or "CDE" has the meaning assigned to that term by subsection 66.2(5) of the Act; (d) "Canadian exploration expense" or "CEE" has the meaning assigned to that term by subsection 66.1(6) of the Act; (e) "Canadian resource property" has the meaning assigned to that term by subsection 66(15) of the Act; (f) "Company" means XXXXXXXXXX, which was incorporated on XXXXXXXXXX under the Business Corporations Act (XXXXXXXXXX), and XXXXXXXXXX; (g) "CRA" means the Canada Revenue Agency; (h) "depreciable property" has the meaning assigned to that term in subsection 13(21) of the Act; (i) "flow-through share" has the meaning assigned to that term by subsection 66(15) of the Act; (j) "Former Mine" means the former producing XXXXXXXXXX mine described in Paragraph 5 of the Facts which was located on the Property; (k) "mineral resource" has the meaning assigned to that term by subsection 248(1) of the Act; (l) "XXXXXXXXXXCo" means XXXXXXXXXX; (m) "NRCan" means Natural Resources Canada; (n) XXXXXXXXXX; (o) "Paragraph" refers to a numbered paragraph in this letter; (p) "principal-business corporation" ("PBC") has the meaning assigned to that term by subsection 66(15) of the Act; (q) "Property" means the mineral claims and mining leases in XXXXXXXXXX that were acquired on XXXXXXXXXX, held 100% by the Company and consists of XXXXXXXXXX mining leases (XXXXXXXXXX) totalling XXXXXXXXXX hectares and XXXXXXXXXX mineral claims (claim # XXXXXXXXXX) totalling XXXXXXXXXX hectares and includes the claims and leases of the Former Mine; (r) "Proposed Transactions" means the transactions described in Paragraphs 21 and 22 below; (s) "public corporation" has the meaning assigned to that term by subsection 89(1) of the Act; (t) XXXXXXXXXX; and (u) "taxable Canadian corporation" has the meaning assigned to that term by subsection 89(1) of the Act. ...

For example, subparagraphs 402(4)(c)(i) and (ii) state, "if the merchandise was produced or manufactured or produced and manufactured, partly in the particular province and partly in another place by the taxpayer, …". ...

Each of these highlighted terms is defined in subsection 118.6(1) of the Act and is explained in more detail in paragraphs 1.9 – 1.25 of Income Tax Folio S1-F2-C1. ...

For additional information on BIL, please see Interpretation bulletin IT-484R2, ARCHIVED – Business Investment Losses, on the CRA's web site. ...

A "Yukon Indian Person", as defined in Chapter 1 of the UFA, is a person enrolled under one of the Yukon First Nation Final Agreements in accordance with criteria established in Chapter 3 — Eligibility and Enrollment. ...

Requirement to file a T106 The requirement to file form T106 – Information return of non-arm’s length transactions with non-residents for a particular taxation year is governed by section 233.1, which falls under Part XV of the Act. ...

Yours truly, XXXXXXXXXX for Division Director Financial Industries and Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch SCHEDULE A – Parties to the Ruling XXXXXXXXXX 1. ...