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Principal Issues: Variation of a trust with unborn beneficiaries- can a Saunders & Vautier variation be made? ...

In addition, lock-up agreements (which the parties called "Voting Agreements") were entered into at various times on or before XXXXXXXXXX between (i) Buyco and Holdco, and (ii) XXXXXXXXXX shareholders and/or optionholders of Target who, in the aggregate, hold approximately XXXXXXXXXX % of the shares of Target, but none of whom individually owns, directly or indirectly, or exercises control over, more than 10% of the common shares of Target. ...

These rulings are given subject to the limitations and qualifications set forth in Canada Customs & Revenue Agency (the "Agency") Information Circular 70-6R3 dated December 30, 1996, and are binding upon the Agency provided the Plan is implemented on or before XXXXXXXXXX. ...

Yours truly, XXXXXXXXXX for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

Principal Issues: An individual's professional corporation will sell XXXXXXXXXX % of its practice to another professional corporation and the individual will resign from the professional corporation and will carry on the balance of the professional corporation's business as a sole proprietor, can the individual's professional corporation pay the individual a retiring allowance? ...

Not inconsistent with ¶ 8 of IT-337R3 and Crighton 91 DTC 511. xxxxxxxxxx xxxxxxxxxx 991042 xxxxxxxxxx XXXXxXxXXX, 1999 Dear Sir/Madam: Re: Advance Income Tax Ruling- XXXXXXXXXX This is in reply to your letter dated XXXXXXXXXX, as amended XXXXXXXXXX, wherein you requested an advance income tax ruling on behalf of the above-noted taxpayer. ...

XXXXXXXXXX 2018-076504 XXXXXXXXXX, 2018 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request – supplement to file 2015-056473 XXXXXXXXXX We are writing in response to your letter of XXXXXXXXXX wherein you advised us of certain changes to the facts and the proposed transactions as they were described in the Advance Income Tax Ruling dated XXXXXXXXXX (2015-056473) subsequently modified by the letter issued by the Canada Revenue Agency (“CRA”) on XXXXXXXXXX (2015-062209) (referred collectively to as the “Original Ruling”) on behalf of the above-referenced taxpayers. ...

2020 Ruling 2020-0869891R3- Supplemental Ruling Unedited CRA Tags 20(1)(c), 112, 245 Principal Issues: Changes to the facts and proposed transactions in advance income tax ruling Position: The rulings in file 2019-081829 will continue to be valid Reasons: The changes do not affect our conclusions XXXXXXXXXX 2020-086989 XXXXXXXXXX, 2020 Re: Advance Income Tax Ruling Request – supplement to file 2019-081829 XXXXXXXXXX We are writing in response to your letter of XXXXXXXXXX. ...

16 June 1989 Ruling 73791 F- Annuity Agreement with a Registered Charity Unedited CRA Tags 118.1(3), 60(a), 56(1)(d), 104, 75(2)(a)(i)   June 16, 1989 Enquiries and Taxpayer Specialty Rulings Assistance Division Directorate P. ...

XXXXXXXXXX 2022-094923 XXXXXXXXXX, 2022 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request – Supplement to file 2020-087076 XXXXXXXXXX We are writing in response to your email of XXXXXXXXXX wherein you submitted a request to make certain changes to the proposed transactions as they were described in the Advance Income Tax Ruling dated XXXXXXXXXX (2020-087076) (referred to as the “Original Ruling”) on behalf of the above-referenced taxpayers. ...