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Ruling

2009 Ruling 2009-0344191R3 - Loss Consolidation

Holdco's current leverage ratio is approximately XXXXXXXXXX %. As the markets are currently favourable, Holdco intends to increase its leverage ratio to approximately XXXXXXXXXX %. 6. ... Simple interest will accrue on Lossco 1 Loan and Lossco 2 Loan and will be calculated at a rate that would not exceed a reasonable rate and is expected to be approximately XXXXXXXXXX %. ...
Ruling

2009 Ruling 2009-0343391R3 - Partnership Reorg-Personal Services Business

It includes the Professional and Non-Professional Services conducted by the Partners on behalf of the Partnership; (q) "Professional Services" means the practice of XXXXXXXXXX; (r) "Proposed Transactions" means the transactions listed in Paragraphs 11 to 31; (s) "Related Persons" has the meaning assigned in subsection 251(2) of the Act; (t) "Small Business Deduction" has the meaning assigned by subsection 125(1) of the Act; (u) "Specified Partnership Income" has the meaning assigned by subsection 125(7) of the Act; (v) "Tax Year" means the fiscal period of the Partnership which, for tax purposes is the calendar year; (w) "Taxable Canadian Corporation" has the meaning assigned by subsection 89(1) of the Act; (x) "XXXXXXXXXX " refers to XXXXXXXXXX., a Taxable Canadian Corporation incorporated under the laws of XXXXXXXXXX, and which is a CCPC carrying on the active business of providing support services to the Partnership. ... (f) Ordinary partnership matters require approval of not less than XXXXXXXXXX % of the Partners. ... Extraordinary matters must be approved by not less than XXXXXXXXXX % of the Partners. ...
Ruling

2007 Ruling 2006-0219051R3 - Loss-Utilization Proposal

Target will borrow an amount of approximately $XXXXXXXXXX on a "daylight loan" basis from an Arm's Length financial institution (the "First Daylight Loan "). 28. ... Bidco will lend the $XXXXXXXXXX of proceeds it receives from the Bidco Loan to Target on a demand basis (the "Target Loan "). ... The contribution of capital, if any, will not be treated as income of Newco II pursuant to generally accepted accounting principles in Canada; b) Target will borrow $XXXXXXXXXX on a "daylight loan" basis from an Arm's-Length financial institution (the "Second Daylight Loan "). ...
Ruling

2007 Ruling 2007-0232261R3 - Post butterfly transaction

The Common Shares held by A Co represent XXXXXXXXXX % of the issued and outstanding Common Shares of XXXXXXXXXX Co. ... The Common Shares held by B Co represent XXXXXXXXXX % of the issued and outstanding Common Shares of XXXXXXXXXX Co. ... The Common Shares held by C Co represent XXXXXXXXXX % of the issued and outstanding Common Shares of XXXXXXXXXX Co. ...
Ruling

2005 Ruling 2005-0117591R3 - Reorganization of a mutual fund trust

(Opco & Holdco amalgamate to form Amalco I. A subsidiary corporation (GPco) 100% owned by Fund will be created. GPco & Amalco I will form a Partnership with Amalco I transferring all former operating assets on a rollover basis. ... Newco & Amalco I will amalgamate to form Amalco II. Fund will use 132.2 to acquire all the assets of Amalco II and become the limited partner of the Partnership. ...
Ruling

2006 Ruling 2006-0171431R3 - Innovative Instrument

The Special Trust Securities will represent not more than XXXXXXXXXX % of the total capital of the Trust represented by units (determined by fair market value and without regard to any voting rights attaching to the units of the Trust), will be voting, subscribed for with cash and will be owned at all material times by ACO. ... The expected aggregate amount of this offering is between $XXXXXXXXXX and $XXXXXXXXXX. 8) XXXXXXXXXX 1 on each Regular Distribution Date up to and including XXXXXXXXXX, representing an XXXXXXXXXX % of the initial issue price. ... Interest on the ACO XXXXXXXXXX Note will be payable XXXXXXXXXX at a fixed annual rate of XXXXXXXXXX % up to and including XXXXXXXXXX, and thereafter at an annual rate equal to the Bankers' Acceptance Rate in effect during the immediately preceding Distribution Period plus XXXXXXXXXX%. ...
Ruling

2017 Ruling 2016-0663831R3 - Standard Loss Consolidation

Profitco’s taxable income for its XXXXXXXXXX prior taxation years for which tax returns have been filed with the CRA is as follows: Taxation Year Ending Taxable Income / (loss) XXXXXXXXXX XXXXXXXXXX 8. ... Profitco has a permanent establishment in each of the provinces and territories listed below and, for its taxation year ending XXXXXXXXXX, its gross revenue and salaries and wages for purposes of Part IV of the Regulations was allocated as follows: Province/Territory Gross Revenue Salaries & Wages Percentage XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX 11. ... Lossco 1 has a permanent establishment in each of the provinces and territories listed below and, for its taxation year ending XXXXXXXXXX, its gross revenue and salaries and wages for purposes of Part IV of the Regulations was allocated as follows: Province/Territory Gross Revenue Salaries & Wages Percentage XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX 15. ...
Ruling

30 November 1997 Ruling 9821803 - AMALGAMATIONS

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 judgment has been issued, the time limit for appeal to a higher court has not expired. ... At XXXXXXXXXX, the number of Class A, B and C shares of Coop #1 and their paid-up amounts were as follows: Class # of Shares Paid-Up Amount A XXXXXXXXXX XXXXXXXXXX B XXXXXXXXXX XXXXXXXXXX C XXXXXXXXXX XXXXXXXXXX 9. The distribution of the Class A, B and C shares as of XXXXXXXXXX, is as follows (some members owned shares of more than one class; many members do not own shares of any class): Class # of Members A XXXXXXXXXX B XXXXXXXXXX C XXXXXXXXXX The Class A shares have been issued only to members and employees of Coop #1 on the conversion of an existing loan account. ...
Ruling

2001 Ruling 2001-0075693 - REIT Voting/Income Rights

The Trust is authorized to issue an unlimited number of units ("Units") of one class, each of which represents a unitholder's ("Unitholder's ") proportionate undivided beneficial interest in the Trust. 8. ... The Declaration of Trust will provide that XCo and its affiliates will be entitled to enhanced voting rights (" the Voting Right"), provided that XCo and its affiliates directly or indirectly beneficially own or control at least XXXXXXXXXX Units subject to the Voting Right and the XCo Group directly or indirectly beneficially owns or controls at least 10% of all outstanding Units (the "Minimum Ownership Threshold"). ... For clarity, the Prospectus will describe that the distributions paid to XCo and its affiliates on up to XXXXXXXXXX Units that are subject to the Voting Right, will be XXXXXXXXXX % less than distributions paid on each other Unit. ...
Ruling

2001 Ruling 2001-0097813 - Spin-off active business invested asssets

The issued and outstanding share capital of DCo is as follows: Paid-up Capital ($) XXXXXXXXXX Class A voting common shares XXXXXXXXXX XXXXXXXXXX Class B voting common shares XXXXXXXXXX XXXXXXXXXX Class C non-voting common shares XXXXXXXXXX 5. The holders of the issued and outstanding common shares of DCo and their ACB are as follows: Name Number and Class ACB $ Mr. ... As a result of the directors' resolution, the issued and outstanding common shares of DCo will be held as follows: Name Number and Class % of outstanding common shares Mr. ...

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