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Ruling
2006 Ruling 2006-0191591R3 - Sequential Butterfly Reorganization
The DC Special Shares will have the following terms and conditions: (a) each DC Special Share will be redeemable, subject to applicable law, at any time at the option of DC at a redemption amount equal to the amount obtained by the formula (A/B x C)/D, where A equals the net FMV of the DC Real Property and the Subco Common Shares immediately before the distribution described in Paragraph 41; B equals the net FMV of all of the business property of DC immediately before the distribution described in Paragraph 41; C equals the aggregate FMV of all DC's issued and outstanding shares determined immediately before the DC share exchanges described in Paragraph 33; and D equals the number of DC Special Shares issued on the DC share exchanges described in Paragraph 33, plus any declared but unpaid dividends; (b) each DC Special Share will be retractable, subject to applicable law, at any time at the option of the holder at a retraction amount equal to the redemption amount described in (a) above; (c) the holder of each DC Special Share will be entitled to a non-cumulative XXXXXXXXXX % cash dividend as and when declared by the board of directors from time to time, which dividend need not also be declared on any other class of shares of DC; (d) there will be a provision restricting the payment of dividends on other classes of shares so that no such dividends may be paid on any other class of shares of DC if the resulting realizable value of the net assets of DC after payment of the dividends would be less than the aggregate of the redemption amounts of all of the DC Special Shares then outstanding; (e) the holder of each DC Special Share will be entitled, upon the liquidation, dissolution or winding-up of DC, to a payment in priority to all other classes of shares of DC ranking junior to the DC Special Shares of an amount equal to the redemption amount thereof to the extent of the amount or value of property available under applicable law for payment to shareholders upon dissolution, but will be entitled to no more than the amount of that payment; and (f) the holder of each DC Special Share will not be entitled to vote at meetings of shareholders of DC. ... The TC Special Shares will have the following terms and conditions: (a) each TC Special Share will be redeemable, subject to applicable law, at any time at the option of TC at a redemption amount equal to the aggregate FMV of the consideration for which such share was issued divided by the total number of issued TC Special Shares (plus any declared but unpaid dividends); (b) each TC Special Share will be retractable, subject to applicable law, at any time at the option of the holder at a retraction amount equal to the redemption amount described above; (c) the holder of each TC Special Share will be entitled to a non-cumulative XXXXXXXXXX % cash dividend as and when declared by the board of directors from time to time, which dividend need not also be declared on any other class of shares of TC; (d) there will be a provision restricting the payment of dividends on other classes of shares so that no such dividends may be paid on any other class of shares of TC if the resulting realizable value of the net assets of TC after payment of the dividends would be less than the aggregate of the redemption amounts of all of the TC Special Shares then outstanding; (e) the holder of each TC Special Share will be entitled, upon the liquidation, dissolution or winding-up of TC, to a payment in priority to all other classes of shares of TC ranking junior to the TC Special Shares of an amount equal to the redemption amount thereof to the extent of the amount or value of property available under applicable law for payment to shareholders upon dissolution, but will be entitled to no more than the amount of that payment; and (f) the holder of each TC Special Share will not be entitled to vote at meetings of shareholders of TC. 36. ...
Ruling
2005 Ruling 2005-0111421R3 - Sequential Spin-off Butterfly Reorganization
The DC Sub Special Shares will have the following terms and conditions: (a) each DC Sub Special Share will be redeemable, subject to applicable law, at any time at the option of DC Sub at a redemption amount equal to the amount obtained by the formula (A/B x C), where A equals the net FMV of the DC Sub Spin-Off Property immediately before the distribution described in Paragraph 23; B equals the net FMV of all of the business property of DC Sub immediately before the distribution described in Paragraph 23; and C equals the aggregate FMV of a DC Sub Common Share determined immediately before the DC Sub share exchanges described in Paragraph 16; plus any declared but unpaid dividends; (b) each DC Sub Special Share will be retractable, subject to applicable law, at any time at the option of the holder at a retraction amount equal to the redemption amount described above; (c) the holder of each DC Sub Special Share will be entitled to a non-cumulative XXXXXXXXXX % cash dividend as and when declared by the board of directors from time to time, which dividend need not also be declared on any other class of shares of DC Sub; (d) there will be a provision restricting the payment of dividends on other classes of shares so that no such dividends may be paid on any other class of shares of DC Sub if the resulting realizable value of the net assets of DC Sub after payment of the dividends would be less than the aggregate of the redemption amounts of all of the DC Sub Special Shares then outstanding; (e) the holder of each DC Sub Special Share will be entitled, upon the liquidation, dissolution or winding-up of DC Sub, to a payment in priority to all other classes of shares of DC Sub ranking junior to the DC Sub Special Shares of an amount equal to the redemption amount thereof to the extent of the amount or value of property available under applicable law for payment to shareholders upon dissolution, but will be entitled to no more than the amount of that payment; and (f) the holder of each DC Sub Special Share will not be entitled to vote at meetings of shareholders of DC Sub. ... The TC Special Shares will have the following terms and conditions: (a) each TC Special Share will be redeemable, subject to applicable law, at any time at the option of TC at a redemption amount equal to the aggregate FMV of the consideration for which such share was issued divided by the total number of issued TC Special Shares (plus any declared but unpaid dividends); (b) each TC Special Share will be retractable, subject to applicable law, at any time at the option of the holder at a retraction amount equal to the redemption amount described above; (c) the holder of each TC Special Share will be entitled to a non-cumulative XXXXXXXXXX % cash dividend as and when declared by the board of directors from time to time, which dividend need not also be declared on any other class of shares of TC; (d) there will be a provision restricting the payment of dividends on other classes of shares so that no such dividends may be paid on any other class of shares of TC if the resulting realizable value of the net assets of TC after payment of the dividends would be less than the aggregate of the redemption amounts of all of the TC Special Shares then outstanding; (e) the holder of each TC Special Share will be entitled, upon the liquidation, dissolution or winding-up of TC, to a payment in priority to all other classes of shares of TC ranking junior to the TC Special Shares of an amount equal to the redemption amount thereof to the extent of the amount or value of property available under applicable law for payment to shareholders upon dissolution, but will be entitled to no more than the amount of that payment; and (f) the holder of each TC Special Share will not be entitled to vote at meetings of shareholders of TC. 36. ...
Ruling
2017 Ruling 2017-0699201R3 - Cross-border Butterfly
The aggregate FMV, immediately before the DC Transfer 2, of the Foreign Spinco common shares owned by Foreign Parentco will be equal to or approximate the amount determined by the following formula, on the assumption that Foreign Parentco is the participant, DC is the distributing corporation and Foreign Spinco is the acquiror, (A × B/C) + D as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1). ...
Ruling
30 November 1996 Ruling 9729323 - DPS
The TSO, taxation centre ("TC"), and the Revenue Canada account number ("RCT #") of the various members of XXXXXXXXXX are as follows: Corporation TSO\TC RCT # XXXXXXXXXX 11. ...
Ruling
2000 Ruling 1999-0011213 - public corporation spin-off
In all cases, the exercise price of each XXXXXXXXXX/Fco Option outstanding under the XXXXXXXXXX/Fco Plan is not less than XXXXXXXXXX % of the fair market value of the shares for which such option was exercisable at the time the option was granted. ... XXXXXXXXXX/Aco will own approximately XXXXXXXXXX % of the issued and outstanding XXXXXXXXXX/Ico Common Shares. ...
Ruling
2019 Ruling 2018-0781491R3 - Split-up Butterfly
Immediately following the DC Transfers, the FMV of each type of property transferred to each of Son Newco and Daughter Newco will be equal to or approximate the proportion determined by the formula: A * B / C Where: A is the FMV, immediately before the DC Transfers, of all property of that type owned at that time by DC; B is the aggregate FMV, immediately before the DC Transfers, of all of the shares of the capital stock of DC, owned at that time by Sonco or Daughter Holdco, as the case may be; and C is the aggregate FMV, immediately before the DC Transfers, of all the issued and outstanding shares of the capital stock of DC. 49. ...
Miscellaneous severed letter
30 October 1992 Income Tax Severed Letter 2M0333A - Published Version of 1991 Canadian Tax Foundation
30 October 1992 Income Tax Severed Letter 2M0333A- Published Version of 1991 Canadian Tax Foundation Unedited CRA Tags 30 / Various / Divers Revenue Canada Round Table Table Ronde de Revenu Canada* Robert M. ...
Miscellaneous severed letter
7 July 2006 Income Tax Severed Letter 2006-0177341R3 - Creation of an income trust
XXXXXXXXXX There are XXXXXXXXXX FCo XXXXXXXXXX Shares; “eligible property” has the meaning assigned by subsection 85(1.1); “ First Act ” means the Canada Business Corporations Act; “First Exchange” means XXXXXXXXXX; “forgiven amount” has the meaning assigned by subsections 80(1) and 80.01(1); “Fund Trustees” means a group of XXXXXXXXXX persons who will be elected by Unitholders in accordance with the Fund Declaration of Trust to act as trustees of New Fund, subject to the terms of the XXXXXXXXXX Agreement. ...
Ruling
2022 Ruling 2020-0873371R3 - Multi-wing split-up net asset butterfly
LP4 owns an interest in joint ventures, mortgages receivable and land inventory which include the following: • XXXXXXXXXX. ... The issued and outstanding share capital of Holdco 2 is held as follows: Shareholder Class of Shares Number of Shares Owned PUC = ACB Siblingco 2 Class A common XXXXXXXXXX XXXXXXXXXX Class A preference XXXXXXXXXX XXXXXXXXXX Class C preference XXXXXXXXXX XXXXXXXXXX Class D preference XXXXXXXXXX XXXXXXXXXX Class F-1 preference XXXXXXXXXX XXXXXXXXXX Class G preference XXXXXXXXXX XXXXXXXXXX Siblingco 3 Class A common XXXXXXXXXX XXXXXXXXXX Class A preference XXXXXXXXXX XXXXXXXXXX Class C preference XXXXXXXXXX XXXXXXXXXX Class D preference XXXXXXXXXX XXXXXXXXXX Class F-2 preference XXXXXXXXXX XXXXXXXXXX Class G preference XXXXXXXXXX XXXXXXXXXX Indirect Holdco 6 Sub Class E preference XXXXXXXXXX XXXXXXXXXX The Class A common shares of Holdco 2 are voting (XXXXXXXXXX vote per share), while all of the preference shares are non-voting and non-convertible. 17. ...
Ruling
2007 Ruling 2006-0215751R3 - Cross-border butterfly
The aggregate FMV, immediately before the transfer of the Newco Common Shares by Canco to Tco described in Paragraph 44, of the Foreign Spinco membership interests owned by Foreign Pubco will be equal to or approximate the amount determined by the formula, on the assumption that Foreign Pubco is the participant, Canco is the distributing corporation and Foreign Spinco is the acquiror, (A x B/C) + D as found in subparagraph (b)(iii) of the definition of "permitted exchange" in subsection 55(1). 33. ...