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2018 Ruling 2017-0711071R3- Use of subsidiary losses & ITCs after wind-up-- summary under Paragraph 88(1.1)(b) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1.1)- Paragraph 88(1.1)(b) streamed losses of empty-shell Lossco flowed through on its dissolution as Lossco LP business had been acquired years earlier through sub LP Acquisition of Lossco business Subsequently to a CCAA filing by Lossco and members of its group, Taxpayer (a wholly-owned subsidiary of a Luxembourg company held by a group of (perhaps U.S.) investors), as limited partner, and its wholly-owned subsidiary, as GP, formed Lossco Business LP, which then acquired the business (the "Lossco Business”) of Lossco pursuant to the “Asset Sale Agreement”. ...

2020 Ruling 2019-0799981R3- Disposition – Reclassification and Stock Split-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition a simultaneous consolidation of 7 identical series of common shares into 1 series, and a stock split, did not effect a disposition Current structure USco is a US-resident corporation that is subject to tax in Canada and the US (in each case, as a regarded corporation). ...

2013 Ruling 2012-0467721R3- IV(7)(b) & PUC increase-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 two-step distribution to two S-Corp shareholders of ULC/interest payment to one USCo and USCo2 are each S Corporations whose shares are owned in the same proportions by U.S. ...

2016 Ruling 2015-0571441R3- Dutch Cooperative- 93.2 & 95(2)(c)-- summary under Paragraph 95(2)(c) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(c) rollover is available on joint drop-down of shares of a Dutch private limited liability company into a Dutch cooperative in consideration for respective credits to the membership accounts Current structure Forco 1 is held through three stacked Canadian partnerships by two taxable Canadian corporations (Canco 1D and Canco 1A) which, in turn, are indirect wholly-owned subsidiaries of a non-resident parent (“Parent”). ...

Preliminarily to this spin-off, an indirect Canadian subsidiary of Foreign Pubco (Canco – which is the distributing corporation) will transfer the Canadian business relating to Business B as well as related foreign subsidiaries held directly (Forsub) or through a partnership (Forlp) and a partner thereof (Canco Sub 4) to the transferee corporation (TCo – a ULC). ... TCo (through transactions which are heavily redacted – see perhaps para. 122) will be indirectly transferred to Foreign Pubco, whereas Canco will become an indirect subsidiary of Foreign Spinco. Indemnity – effect on net value of types of property In order to accomplish the butterfly spin-off of Canco's portion of Business B, Canco will first transfer such assets to Newsub under s. 85(1). ...

For example: The RestaurantCo certificate offers discounts at […] locations in […] [Participating Province X]. ... The certificate has a value of over $[…] and is sold for $19.99. It has four components: A single use [dining] offer of a […]% discount on food total (maximum value $[…]) […] free dinner entrees: Buy one, get one […] free lunch entrees: Buy one, get one Purchaser will receive $[…] in RestaurantCo cash with every catered order over $[…] CRA rules that the certificates are not gift certificates for GST purposes, as they do not have a monetary value. ...

Ruling that the transfers from the Direct Subtrusts to Trust A in 2 will not be considered a "disposition" by virtue of s. 248(1) – disposition, (f)(v), and Trust A will be deemed, to be the same trust as, and a continuation of, each of the Direct Subtrusts by virtue of s. 248(25.1); therefore the ACB of Taxpayer's interest in Trust A will be equal to the aggregate ACB of Taxpayer's interests in the Direct Subtrusts before the transfer. See detailed summary under s. 132.2 – qualifying exchange. ...

See detailed summary under s. 132.2 – qualifying exchange. ...

. … Opco may advance funds to the LP from time to time for working capital and development… on arm's length commercial terms…. ...

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