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Ruling

2007 Ruling 2007-0224131R3 - wind up of a personal trust

XXXXXXXXXX 2007-022413 Attention: XXXXXXXXXX XXXXXXXXXX, 2007 Dear XXXXXXXXXX: Re: XXXXXXXXXX Advance Income Tax Ruling Account # XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX in which you request an advance income tax ruling in respect of the above-noted taxpayer. ... XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling

2007 Ruling 2007-0252501R3 - Loss Consolidation

Unless otherwise stated, all statutory references are to the Act and all terms and conditions used herein that are defined in the Act have the meaning given in such definition; (b) "affiliated persons" has the meaning assigned by subsection 251.1(1) of the Act; (c) "arm's length" has the meaning assigned by subsection 251(1) of the Act; (d) "Canadian-controlled private corporation" has the meaning assigned by subsection 125(7) of the Act; (e) "CBCA" means the Canada Business Corporations Act; (f) "CRA" means the Canada Revenue Agency; (g) "Daylight Loan" means the amount of $XXXXXXXXXX or such lesser amount to be borrowed by Profitco from an arm's length financial institution on a "daylight loan" basis and invested by Profitco in the Lossco Preferred Shares; (h) "dividend rental arrangement" has the meaning assigned by subsection 248(1) of the Act; (i) "EBITDA" means earnings before interest, taxes, depreciation and amortization; (j) "Facility" means the XXXXXXXXXX, which is owned and operated by Lossco; (k) "financial intermediary corporation" has the meaning assigned by subsection 191(1) of the Act; (l) "forgiven amount" has the meaning assigned by subsection 80(1) of the Act; (m) "Lossco" means XXXXXXXXXX; (n) "Lossco Loan" means the demand loan made by Lossco to Profitco referred to in 22 below, bearing an annual rate of simple interest of XXXXXXXXXX % calculated daily which is not greater than the rate Profitco would pay to an arm's length lender to borrow an equivalent amount on similar terms. ... The remaining XXXXXXXXXX issued and outstanding common shares of Lossco, representing XXXXXXXXXX % of its issued and outstanding shares and shareholder equity of $XXXXXXXXXX, are owned by Xco. ...
Ruling

2008 Ruling 2007-0259901R3 - Loss utilization

Parent will use the total proceeds received from the Daylight Loan 2 to make a loan of $XXXXXXXXXX to A Co ("A Co Loan 2 "). ... (c) Newco will use the funds ($XXXXXXXXXX + the amount of the contribution of capital, if any) received through step (a) and (b) above, to redeem Preferred Shares Series 1 and Preferred Shares Series 2 held by A Co (including any accrued dividends). ...
Ruling

2006 Ruling 2005-0151051R3 F - Entente d'échelonnement de traitement

(g) "Acquisition du Contrôle" signifie acquisition du contrôle de OPCO et pour les fins du Régime inclut les situations où il y aurait un changement dans la propriété de plus de 50 % des actions ordinaires émises et en circulation du capital-actions de OPCO, la situation où les actionnaires de OPCO approuveraient la liquidation ou la dissolution de la société et la situation où OPCO deviendrait une société publique au sens de la Loi. ... (r) "Unité " signifie les unités attribuées aux Employés Admissibles dans le cadre du régime. ...
Ruling

2006 Ruling 2006-0184821R3 - Proposed PUC reduction by a public corporation

Of these, Pubco owns XXXXXXXXXX common shares of Subco (representing XXXXXXXXXX% of the outstanding common shares and votes) while the XXXXXXXXXX investors continue to hold an aggregate of XXXXXXXXXX common shares of Subco (representing XXXXXXXXXX % of the outstanding common shares and votes). 8. ... This Distribution is intended to represent a one-time distribution of the common shares of Subco by Pubco leaving Pubco with approximately XXXXXXXXXX % of the issued and outstanding common shares of Subco. ...
Ruling

2005 Ruling 2004-0108281R3 - Inducement payment and ACB of shares

Additionally, B Co owns XXXXXXXXXX shares of A Co representing XXXXXXXXXX % of the issued and outstanding shares of A Co which it acquired during the period commencing in XXXXXXXXXX and ending in XXXXXXXXXX. ... To $ Amount B Co $XXXXXXXXXX A Co $XXXXXXXXXX 15. B Co will use the monies received from Strategico as described in paragraph 14 above to subscribe for additional B Subco common shares and having an aggregate fair market value equal to the aggregate consideration paid of US$XXXXXXXXXX. 16. ...
Ruling

30 November 1995 Ruling 9625783 - ASSET SALE- EVENT OF DEFAULT

2.Does a failure to make an offer if there is " Excess proceeds" from an Asset Sale an acceptable event of default? ... To the extent the net proceeds are not so applied or invested, they are defined as " Excess Proceeds". 18.When the aggregate amount of Excess Proceeds exceeds XXXXXXXXXX, the Issuers will be required to make an offer to all holders of Notes to purchase the maximum principal amount of Notes that may be purchased out of the Excess Proceeds, in cash at a price equal to XXXXXXXXXX% of the principal amount plus accrued and unpaid interest to date of purchase (hereinafter "Asset Sale Offer"). 19.To the extent the amount of Notes tendered pursuant to an Asset Sale Offer is less than the Excess Proceeds, the Issuers may use any remaining Excess Proceeds for general corporate purposes. ...
Ruling

30 November 1997 Ruling 9803323 - INTEREST DEDUCTIBILITY

Purpose and use of borrowing is to acquire preferred shares of Newco having a dividend rate > interest rate on borrowing. ... The cumulative dividends payable on the preferred shares will be calculated daily by reference to the redemption/retraction price of the preferred shares at a rate equal to XXXXXXXXXX % and will be payable annually in arrears on or before the year-end. 18. ...
Ruling

27 January 1994 Ruling 9333591 F - Trucks Hauling Wood Chips - Qualified Property?

Additional Considerations 1.     Document #E72960 written in response to a memorandum dated June 20, 1988, contained an opinion that, in the facts of the situation under consideration, a woodchipper was being used primarily in a logging activity. ... It should also be noted that, although tractor-trailer trucks owned by a related company were also considered in that document, based upon the facts presented, it would appear that they were used primarily to transport pulpwood or logs rather than wood chips. 2.      ...
Ruling

2003 Ruling 2003-0037453 - LOSS CONSOLIDATION

XXXXXXXXXX % of Lossco's salaries and wages and gross revenue are generated in XXXXXXXXXX. 3. ... As the current line of credit is at approximately $XXXXXXXXXX, the transactions described in Paragraphs 15 & 16 will be repeated XXXXXXXXXX times, over a period of XXXXXXXXXX days as follows. ...

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