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Our understanding of the facts, proposed transactions and the purpose of the proposed transactions is as follows: Definitions "Accumulated Unpaid XXXXXXXXXX" means, at any time, an amount, if any, per Trust Security equal to the XXXXXXXXXX payable by the Trust thereon in respect of all previous Regular Distribution Dates remaining unpaid by the Trust; "Automatic Exchange" has the meaning set out in paragraph 16 below; "XXXXXXXXXX" means the XXXXXXXXXX (Canada); "Capital Guidelines" means the guidelines issued by the Superintendent concerning the maintenance of adequate capital for Canadian chartered banks and federally-regulated trust and loan companies; "Cash Redemption Price" means $XXXXXXXXXX together with any declared and unpaid dividends on Exchange Preferred Shares, as applicable; "Common Share Conversion Rate" has the meaning set out in paragraph 29 below; "Current XXXXXXXXXX" means, in respect of the period from and including the last Distribution Date, an amount per Trust Security XXXXXXXXXX pro-rated for the number of days elapsed from and including the last Distribution Date to but excluding the date of the redemption or termination, as the case may be, provided that there has not been a Distribution Diversion Event with respect to the Distribution Date that would next occur but for such redemption or termination; "XXXXXXXXXX Note" has the meaning set out in paragraph 20 below; XXXXXXXXXX; "XXXXXXXXXX Note Early Redemption Price" means an amount equal to the greater of (A) the XXXXXXXXXX Note Redemption Price, and (B) XXXXXXXXXX; "XXXXXXXXXX Note Interest Payment Date" means XXXXXXXXXX; "XXXXXXXXXX Note Redemption Price" means $XXXXXXXXXX plus any accrued and unpaid interest thereon per $XXXXXXXXXX principal amount of the XXXXXXXXXX Note to be redeemed; "Distribution Date" means XXXXXXXXXX; "Distribution Diversion Date" means a Distribution Date in respect of which there has occurred a Distribution Diversion Event; "Distribution Diversion Event" means XXXXXXXXXX Common Shares, in a particular period that is used to determine whether a Distribution Date is a Regular Distribution Date or a Distribution Diversion Date; "Dividend Payment Date" means XXXXXXXXXX; "Early Redemption Price" means an amount equal to the greater of (A) the Redemption Price, and (B) XXXXXXXXXX; "Eligible Investments" means the Funding Note or any property, including money, securities, amounts receivable from unrelated third parties, mortgages, an interest in an Eligible Investment, and any debt obligation, that is a qualified investment under the Act for plans and funds described in subsection 204.4(1) (except where the qualification of such property contains conditions regarding the annuitant, the beneficiary, the employer or the subscriber under the plan or fund unless the Trust is satisfied that such conditions are satisfied), except that the XXXXXXXXXX Note will not be repaid with or converted or exchanged into debt of X.Co. or a related person and, following the maturity of the XXXXXXXXXX Note, the proceeds of repayment of the XXXXXXXXXX Note will not be invested in debt of X Co. or a related person; "Exchange Preferred Shares" means, collectively, the Preferred Shares XXXXXXXXXX W and the Preferred Shares XXXXXXXXXX X; "Exchange Trustee" has the meaning set out in paragraph 17 below; "Funding Note" has the meaning set out in paragraph 20 below; XXXXXXXXXX; "Holder Exchange Right" has the meaning set out in paragraph 14 below; XXXXXXXXXX; "XXXXXXXXXX Event" means XXXXXXXXXX; XXXXXXXXXX; "Preferred Shares XXXXXXXXXX W" has the meaning set out in paragraph 2 below; "Preferred Shares XXXXXXXXXX X" has the meaning set out in paragraph 2 below; "Redemption Price" means $XXXXXXXXXX per Trust Security together with any Unpaid XXXXXXXXXX to the date of redemption; "Regular Distribution Date" means a Distribution Date other than a Distribution Diversion Date; XXXXXXXXXX; "Share Exchange Agreement" has the meaning set out in paragraph 17 below; "Special Security(ies)" has the meaning set out in paragraph 7 below; "Superintendent" means the Superintendent of Financial Institutions (Canada); "Surrender Price" has the meaning set out in paragraph 14 below; XXXXXXXXXX; "XXXXXXXXXX Event" means XXXXXXXXXX; "Tier 1 Guidelines" means the interim guidelines issued by the Superintendent dated August 22, 2001 entitled "Innovative Tier 1 Capital- Interim Appendix to Guideline A Capital Adequacy Requirements (CAR) / Minimum Continuing Capital and Surplus Requirements (MCCSR)"; "Trust" has the meaning set out in paragraph 6 below; "Trust Assets" means the property and assets of the Trust from time to time; "Trustee" has the meaning set out in paragraph 6 below; "Trust Security(ies)" has the meaning set out in paragraph 7 below; XXXXXXXXXX "Unpaid XXXXXXXXXX" means, XXXXXXXXXX; "X Co. ... X Co.'s business number is # XXXXXXXXXX, its Taxation Centre is XXXXXXXXXX, and its Tax Services Office is XXXXXXXXXX. 2. ...

XXXXXXXXXX owns directly XXXXXXXXXX class XXXXXXXXXX common shares of XXXXXXXXXX, representing all of the issued and outstanding class XXXXXXXXXX common shares, which shareholdings represent XXXXXXXXXX % of the issued and outstanding common shares of XXXXXXXXXX. 3. ... XXXXXXXXXX owns directly XXXXXXXXXX class XXXXXXXXXX common shares of XXXXXXXXXX representing all of the issued and outstanding class XXXXXXXXXX common shares, which shareholdings represent XXXXXXXXXX % of the issued and outstanding common shares of XXXXXXXXXX acquired its shareholding in XXXXXXXXXX as a result of a transaction which was the subject of the Butterfly Ruling. 4. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayers or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ... The holders of the issued and outstanding shares of Holdco are as follows: Shareholder Class # of Shares X Class A Preferred XXXXXXXXXX X Class D Preferred XXXXXXXXXX X Class E Preferred XXXXXXXXXX The Trust Common XXXXXXXXXX None of the Holdco shares were acquired by X or the Trust in contemplation of the proposed transactions set forth below. ...

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. ...

According to Directive # 101- 01 entitled “Introduction to the ODSP Employment Supports Directives”, this can be conventional full-time or part-time waged employment, self-employment, membership participation in a business enterprise or contract employment. ... In particular, subparagraph 12(1)(x)(ii) through (iv) would bring into income amounts received by a taxpayer from a government that “... can reasonably be considered to have been received (iii) as an inducement, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of inducement, or (iv) as a refund, reimbursement, contribution or allowance or as assistance, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of assistance, in respect of (A) an amount included in, or deducted as, the cost of property, or (B) an outlay or expense”. ...

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"). ...