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Ruling

30 November 1997 Ruling 9728233 - 21-YEAR DEEMED DISPOSITION RULE

As a result of the election, the deemed realization day for the Trust which would otherwise have occurred on January 1, 1993 pursuant to subsection 104(4)(b) of the Act was deferred toJanuary 1, 1999. ...
Ruling

2001 Ruling 2000-0055923 - Butterfly Reorganization

As the result of the proposed transactions carried out pursuant to advance income rulings issued on XXXXXXXXXX, 1993 (XXXXXXXXXX) the shareholdings of XXXXXXXXXX/Aco were as follows: XXXXXXXXXX shares XXXXXXXXXX preferred shares Shareholder Number Paid-up capital Number Paid-up capital Redemption Amount XXXXXXXXXX XXXXXXXXXX ("XXXXXXXXXX/Father") and XXXXXXXXXX ("XXXXXXXXXX/Mother") were the father and mother of XXXXXXXXXX/Brother 1 and XXXXXXXXXX/Brother 2. 5. ...
Ruling

1998 Ruling 9719943 - BUTTERFLY REORGANIZATION

Prior to March, 1995, the trustees of the Family Trust filed an election pursuant to subsection 104(5.3) to defer the deemed disposition of the property of the Family Trust that otherwise would have occurred on June 30, 1993 pursuant to subsection 104(4). 8. ...
Ruling

31 January 1994 Ruling 9325281 - Réorganisation papillon

Traduit initialement par Phil Diguer, révisé par Carole Pronovost, le cours a été donné en français par Alain Godin aux employés de Revenu Canada à l'Hotel le Dauphin à Drummondville le 22 septembre 1993. ...
Ruling

2009 Ruling 2008-0276061R3 - Spin-off butterfly

(o) Pursuant to subsection 249.1(7) and in accordance with the policies of the CRA set forth in Interpretation Bulletin IT-179R- Change in Fiscal Period, dated May 28, 1993, each of Partnership A, Partnership B and Partnership D requested and subsequently received the concurrence of the Minister of National Revenue for permission to change its fiscal period from XXXXXXXXXX or XXXXXXXXXX, as applicable, to the time that is immediately before the time that is immediately before the time the applicable Partnership ceases to exist, such change in fiscal period being conditional upon: (i) the issuance by the CRA of a favourable advance income tax ruling on the Proposed Transactions; (ii) the dissolutions of the Partnerships occurring in the manner described in such ruling; and (iii) such dissolutions occurring before the proposed amendments that were announced October 29, 2007, in former Bill C-10, to subsection 99(1) are effective. ...
Ruling

2009 Ruling 2009-0338731R3 - Public spin-off butterfly

(o) Pursuant to subsection 249.1(7) and in accordance with the policies of the CRA set forth in Interpretation Bulletin IT-179R- Change in Fiscal Period, dated May 28, 1993, each of Partnership A, Partnership B and Partnership D requested and subsequently received the concurrence of the Minister of National Revenue for permission to change its fiscal period from XXXXXXXXXX or XXXXXXXXXX, as applicable, to the time that is immediately before the time that is immediately before the time the applicable Partnership ceases to exist, such change in fiscal period being conditional upon: (i) the issuance by the CRA of a favourable advance income tax ruling on the Subject Transactions and the Proposed Transactions; (ii) the dissolutions of the Partnerships occurring in the manner described in such ruling; and (iii) such dissolutions occurring before the proposed amendments that were announced October 29, 2007, in former Bill C-10, to subsection 99(1) are effective. ...

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