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2014 Ruling 2014-0518451R3- Loss consolidation-- summary under Paragraph 111(1)(a) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(1)- Paragraph 111(1)(a) losses transferred to new "Aco" which is wound-up into profitco – but borrowing capacity rep of Lossco not Aco/ provincial GAAR ruling/ cashless un-wind Overview Loan 2 (in step 3 below) is being made by Lossco (the wholly-owned loss subsidiary of Parent) to Aco (so as to generate losses in Aco for later transfer under s. 88(1.1) to Opco), instead of being made directly to Opco, "to ensure that Opco, which is a public corporation, does not incur debt in order to implement the loss utilization. ...

Proposed transactions The terms of the Notes A will be amended (but with no novation) to change the governing law and to add a right allowing the holder to exchange them for new Canadian-dollar interest-bearing demand notes ("Notes B"); and a similar exchange right into Canco1 Note B will be added to Canco1 Note A – with both exchange rights then being exercised by Canco3. ...

Accordingly, Fund 1 will purchase currency forward contracts (the "Canadian Hedging Contracts") solely in respect of the Hedged Class, and: The Hedged Class … will have a return that is based on the performance of Fund 1's portfolio of investments without regard for the performance, either positive or negative, attributable to changes in value of the relevant foreign currency relative to the Canadian dollar because the foreign currency exposure of the portion of Fund 1 that is attributable to the Hedged Class will be substantially hedged using the Canadian Hedging Contracts. ...

2016 Ruling 2015-0612931R3- Variation of trust indenture-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition creation of new MFT units to indirectly bear trailer fees Proposed creation of new class of units to fund trailer fees The Declaration of Trust of an open-ended non-SIFT mutual fund trust (the “Trust”) with a corporate trustee (the “Trustee”) and with only one class of units will be amended to create two classes of units, so that the existing units will be re-designated as Class F units and a new class of units (Class A units) will be created which will have the same attributes as the Class F units except that they will bear exclusively an additional management fee, payable by an indirect subsidiary real estate operating LP to its GP (“Operating GP” – controlled by Trustee), which will fund the cost of trailer fees payable to investment dealers who have sold Class A units, with this resulting in a reduction of the distributions paid on the Class A, but not on the Class F, units. ...

Rulings Re qualification of expenditures under CEE – (f) and non-application of s. 245(4), and that s. 66(12.71) will not apply to prevent Bco from renouncing CEE provided that it is carrying on business in Canada. ...

Rulings Including re qualification of expenditures under CEE – (f). ...

Rulings Including that s. 107(2) will apply to the distribution from the Trust of the Real Property to the Beneficiary such that: pursuant to s. 107(2)(a) the Trust will be deemed to have disposed of the Real Property for its cost amount, the Beneficiary will be deemed under s. 107(2)(b) to have acquired it at the same amount and under s. 107(2)(c) to have disposed of part of its capital interest for that amount minus the eligible offset amount, being the amount of the assumed debt, and pursuant to ss. 107(1.1), 107(1)(a), and s. 108(1) – “cost amount”, the adjusted cost base of the part of the capital interest in the Trust to the Beneficiary, immediately before the disposition of such part of the capital interest, will be deemed to be the total of all amounts each of which is the cost amount to the Trust of the distributed properties. ...

CRA reasons (in its summary) The definition of a "participating debt interest" refers to interest "that is paid or payable on an obligation, all or any portion of which …". ...

Parent then amalgamated with Target and the Subco shares were bumped under s. 88(1)(d) – but with the bump amount being reduced by any Subco surpluses described in Reg. 5905(5.4). ...

Purpose of transactions [T]he main purpose of the Proposed Transactions … is to progressively place in the hands of A's heirs certain property whose FMV corresponds to the ACB resulting from the application of subsection 70(5), to the Estate, of the Holdco Shares that were acquired as a result of A's death. ...