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To the best of your knowledge and that of the taxpayer, none of the issues involved in this ruling contained herein is: (i) dealt with in a return of Finco or a related person; (ii) being considered by any tax services office or taxation centre in ` connection with a previously filed tax return of Finco or a related person; (iii) under objection by Finco or a related person; (iv) the subject of a ruling previously issued by the Income Tax Rulings Directorate of the CRA to Finco or a related party; nor (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired. ... The terms of Finco's loan to LP#2 will be identical to the terms of the Finco Loan, other than the interest rate, which will be XXXXXXXXXX % greater than the interest rate on the loan that Finco receives from the Lender. 17. ...

Position: 1 & 2– No. 3– Yes, provided the production does not subsequently become an excluded production (i.e. the 25-year copyright ownership requirement continues to be met) and the production meets the other requirements of a Canadian film or video production under subsection 1106(4) of the Regulations. Reasons: 1 & 2– Clause 1106(1)(a)(iii)(A) of the definition of "excluded production" in the Regulations contemplates a transfer of the copyright between a qualified corporation and a related prescribed taxable Canadian corporation. 3– Wording of provisions (including subsection 1101(5k.1) of the Regulations which contemplates a transfer of the production between a qualified corporation and a related corporation). ...

At the time of the proposed transactions, # Co will have XXXXXXXXXX common share issued and outstanding. 14. ... #Co will use the amounts received as capital contributions to pay dividends on the # Co Preferred Shares at least annually. 27. ...

The Corporation closed a broker private placement of flow-through shares for gross proceeds of approximately $ XXXXXXXXXX on XXXXXXXXXX. ... The above advance income tax rulings are given subject to the general limitations and qualifications set out in Information Circular 70-6R6 — Advance Income Tax Rulings and Technical Interpretations, dated August 29, 2014 and are binding on the CRA provided that the Corporation has commenced implementing the Proposed Transactions before XXXXXXXXXX. ...

Table 1 – Total Revenue and Book net income for USCo and its subsidiaries, the REIT and Canco XXXXXXXXXX Table II – Assets and Payroll expenses XXXXXXXXXX 29. ...

The interest rate on the DutchCo Note is XXXXXXXXXX %. 11. The Consolidated Group carries on a business in the XXXXXXXXXX sector (the "XXXXXXXXXX Business") and it is noted that: a) The XXXXXXXXXX Business consists of XXXXXXXXXX; b) The XXXXXXXXXX Business is the same in both Canada and the U.S.; c) All the persons that carry on the XXXXXXXXXX Business in Canada and the U.S. are related persons to each other within the meaning of subsection 251(2); d) The average annual revenues for the U.S. and Canada over the past two years (XXXXXXXXXX and XXXXXXXXXX), for accounting purposes, are $XXXXXXXXXX and $XXXXXXXXXX, respectively; e) The average number of employees for the U.S. and Canada in the fiscal year ended on XXXXXXXXXX is XXXXXXXXXX and XXXXXXXXXX respectively; f) The average fixed asset base in the U.S. and Canada over the past two years (XXXXXXXXXX and XXXXXXXXXX), for accounting purposes, is $XXXXXXXXXX and $XXXXXXXXXX, respectively; and g) The interest income on the CanSub Note is derived, directly or indirectly, from the XXXXXXXXXX Business carried in Canada through CanSub. 12. ... Yours truly, XXXXXXXXXX Manager for Division Director International Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

Foreign Parent has no physical presence in Canada – it has no directors, officers, employees in Canada; it has no offices situated in Canada or any premises otherwise available to Foreign Parent in Canada. ... Other than the hiring of Employee in Canada, ForCo has no other presence in Canada – it has no directors, officers, employees in Canada; it has no offices situated in Canada or any premises otherwise available to ForCo in Canada. ...

Following the proposed transactions, FA1, FA2, FA3 and FA4 will be able to instead hold shares of FA Holdco XXXXXXXXXX – providing each of FA1, FA2, FA3 and FA4 with a broader exposure to a more diverse real estate investment pool. ... The purpose for FA5, FA7, FA8 and FA9 investing directly in Property Cos is to allow FA5, FA7, FA8 and FA9 continued exposure to real estate investments in a manner that complies with local regulatory requirements – together with the flexibility to invest in FA Holdco if permitted by the relevant local regulatory authorities. ...

The preferential cumulative annual dividends payable on the Preferred Shares will be calculated by reference to the redemption price of the Preferred Shares at a rate equal to the interest rate on the Subsidiary Loan, the proceeds of which were used to acquire the Newco Preferred Shares, plus XXXXXXXXXX %. ... The current market rate is approximately XXXXXXXXXX % per annum. The interest on the Subsidiary Loan will be paid annually on XXXXXXXXXX. 15. ...

DEFINITIONS: In this letter, the following terms have the following meanings: (a) "Administrative Trustee" means a trust company, appointed pursuant to the terms of the Trust Agreement; (b) "Annual Income" means the greater of: (i) all of the income for Canadian federal income tax purposes derived from Trust Property held in or purchased with funds from the Trust Account; and (ii) the amount that is XXXXXXXXXX per cent of the market value of the Authorized Investments held in the Trust Account as at XXXXXXXXXX in each year; (c) "XXXXXXXXXX " means a non-interest bearing loan from the Trust in favour of the Beneficiary in the sum of $XXXXXXXXXX, to be repaid in equal amounts over XXXXXXXXXX years from Annual Income, and which is to be used exclusively by the First Nation for the purpose of capital improvements to the XXXXXXXXXX facilities on the Reserves; (d) "Authorized Investment" means an investment purchased with funds from the Trust Account as selected by an investment manager in accordance with the terms of the Trust Agreement; (e) "Beneficiary" means the First Nation; (f) "Canada" means Her Majesty the Queen in Right of Canada, as represented by the Minister of Aboriginal Affairs and Northern Development; (g) "Chief" means the duly elected Chief of the First Nation; (h) "Community Trustee" means an eligible Member appointed in accordance with the provisions of the Trust Agreement; (i) "Council" means the duly elected Chief and council of the First Nation; (j) "Federal Payment" means the payment received by the First Nation from Canada pursuant to the Settlement Agreement and as described in paragraph 17 of this ruling letter; (k) "INAC" means Aboriginal Affairs and Northern Development Canada, formerly know as Indian and Northern Affairs Canada; (l) "Indian Act" means the Indian Act, R.S.C. 1985, c.I-5, as amended, and the regulations pursuant to the Indian Act; (m) "Initial Capital" means the Federal Payment less any amounts withdrawn to pay outstanding expenses incurred by Council in relation to the negotiation, settlement and ratification of the XXXXXXXXXX; (n) "Initial Settled Property" means the amount of $XXXXXXXXXX received by the Trustees from the First Nation to settle the Trust; (o) "XXXXXXXXXX; (p) "Member" means a person registered from time to time as a member of the First Nation on the XXXXXXXXXX list maintained pursuant to the Indian Act or under XXXXXXXXXX membership code; (q) "Reserves" means the First Nation's reserves as described in paragraph 3 of this ruling letter, which are "reserves" as defined in subsection 2(1) of the Indian Act; (r) "Settlement Agreement" means the agreement made between the First Nation and Canada and ratified by Members on XXXXXXXXXX (s) "XXXXXXXXXX " means the settlement reached between the First Nation and Canada on XXXXXXXXXX (t) "Trust" means the trust established pursuant to the terms of the Trust Agreement for the benefit of the Beneficiary, known as the XXXXXXXXXX; (u) "Trust Account" means all of the accounts established by the Administrative Trustee for the management of the Trust Property; (v) "Trust Agreement" means the agreement made between the First Nation and the Trustees ratified by the eligible Members on XXXXXXXXXX; (w) "Trust Property" means the Initial Capital and all monies and receivables now or hereafter on deposit in the Trust Account, including any and all investment instruments in which the monies in the Trust Account may from time to time be invested, as well as any capital contributions as directed by Council, any additions or accruals thereto, and also includes all interest revenue and other income realized but excluding all amounts which have been paid or disbursed therefrom in the normal course of the administration of or pursuant to the provisions of the Trust Agreement; (x) "Trustees" means the Community Trustees and the Administrative Trustee collectively. ...