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It is also to be noted that in cases involving theatrical shows where performances were given in different places, both the U.S. and New Zealand, which Tax Conventions use the same concepts of "permanent establishment" and "fixed base" as that found in the Convention, denied that a permanent establishment existed (see technical interpretation # E 2000-0036167). ...

Reasons: Similar to ruling # E 2001-0079143 and E 2002-016141 XXXXXXXXXX 2002-016338 XXXXXXXXXX, 2002 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request XXXXXXXXXX This in reply to your letter of XXXXXXXXXX, in which you requested an advance income tax ruling in respect of the income tax consequences arising from the proposed transactions described below. ...

Definitions In this letter, unless otherwise indicated, all statute references are to the Income Tax Act and Regulations, R.S.C. 1985 (5th supp.) c. 1, as amended (the "Act"), and the following terms have the meaning specified: "Amalco" means the corporation that will result from the amalgamation of XXXXXXXXXX Following the amalgamation, XXXXXXXXXX% of the voting shares will be owned indirectly by XXXXXXXXXX and persons related to him and XXXXXXXXXX % of the voting shares will be owned indirectly by XXXXXXXXXX and persons related to him. ...

Yours truly, XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch ...

XXXXXXXXXX 2015-060516 XXXXXXXXXX, 2017 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling – XXXXXXXXXX We are writing in reply to your letter of XXXXXXXXXX, with a subsequent revision on XXXXXXXXXX, in which you requested an advance income tax ruling on behalf of the above-referenced persons. ...

The aggregate adjusted cost base of the common shares of A Co. owned by C Co. is, approximately, $ XXXXXXXXXX. ...

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 judgement has been issued, the time limit for appeal to a higher court has not expired. ...

Reasons: 1) this interpretation is accepted and is described in ¶ 3 or IT-413R 2) The purpose of these arrangements is not to reduce the loss of any partner but to XXXXXXXXXX. ...

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

., 3 & 6. See comments under Position. 4. Because of the 60-month exemption, the trust has no change in residence at the time that the contributor becomes resident in Canada; however the trust does become resident in Canada on January 1 of the year in which the conditions in 94(1)(a) and (b) are met such that a deemed disposition under 128.1(1) occurs before the trust becomes resident in Canada. 5. ...