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Ruling

2012 Ruling 2012-0466731R3 - Donation of flow-through shares

There will be two forms of subscription agreement – one for residents of XXXXXXXXXX under which the Resource Company will incur exploration expenses in XXXXXXXXXX, and one for residents of XXXXXXXXXX under which the Resource Company will incur exploration expenses in XXXXXXXXXX. ...
Ruling

2014 Ruling 2013-0510551R3 - Upstream Loans - Specified Debtor

Yours truly, XXXXXXXXXX Manager for Director International & Partnerships Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling

2013 Ruling 2012-0464841R3 - Distribution by a trust

Opco will reorganize its share capital and will file Articles of Amendment in order to: a) Delete the authorized but unissued non-voting preference shares in their entirety as well as all rights and restrictions attaching thereto; b) Create an unlimited number of Class A common shares, voting (as to XXXXXXXXXX votes per share), carrying the right to dividends declarable at the discretion of the Board of Directors; c) Create an unlimited number of Class B common shares, voting (as to XXXXXXXXXX votes per share), carrying the right to dividends declarable at the discretion of the Board of Directors; d) Create an unlimited number of Class D common shares, voting (as to XXXXXXXXXX votes per share), carrying the right to dividends declarable at the discretion of the Board of Directors; e) Create an unlimited number of Class W common shares, voting (as to XXXXXXXXXX votes per share), carrying the right to dividends declarable at the discretion of the Board of Directors; f) Create XXXXXXXXXX Class A preferred shares which shall be non-voting, carrying annual dividends in the aggregate amount of $XXXXXXXXXX, redeemable and retractable as described in Article XXXXXXXXXX, respectively, of the Articles of Amendment (the "Redemption Amount – Class A"). ...
Ruling

2012 Ruling 2011-0426581R3 - Loss and XXXXXXXXXX tax consolidation

., document # XXXXXXXXXX) for this taxpayer except that the Proposed Transactions not only involve the utilization of Creditco's non-capital losses but also the XXXXXXXXXX tax credits of Creditco in respect of claims made in the XXXXXXXXXX to XXXXXXXXXX taxation years, and in the current and future taxation years. ...
Ruling

2012 Ruling 2011-0431051R3 - Charity's interest in a taxable corporation

With the exception of XXXXXXXXXX support, the XXXXXXXXXX program functions separately from the remaining operations of the Charity, including with respect to matters involving XXXXXXXXXX – all of which are the responsibility of a committee of the XXXXXXXXXX, not the Charity's Board of Directors. 7. ...
Ruling

2014 Ruling 2013-0516071R3 - Reorganization

Unless otherwise stated, all statutory references herein are to the Act; "ACB" is the acronym for "adjusted cost base," which has the meaning assigned by section 54; "Amalco" has the meaning assigned in paragraph 26; "Amalco Preferred Shares" has the meaning assigned in paragraph 26; "Amalco Preferred Share Redemption Amount" has the meaning assigned in paragraph 26; "Amalco Redemption Note" has the meaning assigned in paragraph 28(c); "CRA" means Canada Revenue Agency; "dollars" or "$" means Canadian dollars; "EAI" is the acronym for "eligible alignment income" which has the meaning assigned in subsection 34.2(1); "Foreign Parent 1" means XXXXXXXXXX, a XXXXXXXXXX corporation; "Foreign Parent 2" means XXXXXXXXXX, a XXXXXXXXXX corporation; "GPco 1" means XXXXXXXXXX, an unlimited liability company governed by the XXXXXXXXXX; "GPco 2" means XXXXXXXXXX, an unlimited liability company governed by the XXXXXXXXXX; "Lossco" means XXXXXXXXXX, a corporation governed by the XXXXXXXXXX; "Lossco Preferred Shares" has the meaning assigned in paragraph 21; "Lossco Preferred Share Redemption Amount" has the meaning assigned in paragraph 21(b); "LP1" means XXXXXXXXXX, a partnership governed by the XXXXXXXXXX; "LP1 Units" mean the limited partnership units of LP1; "LP2" means XXXXXXXXXX, a partnership governed by the XXXXXXXXXX; "LP2 Units" means the limited partnership units of LP2; "multi-tier alignment election" has the meaning assigned by subsection 249.1(9); "Newco" has the meaning assigned in paragraph 23; "Profitco" means XXXXXXXXXX, a corporation governed by the XXXXXXXXXX; "Profitco Preferred Shares" has the meaning assigned in paragraph 22; "Profitco Preferred Share Redemption Amount" has the meaning assigned in paragraph 22(b); "Profitco Redemption Note" has the meaning assigned in paragraph 28(d); "QTI" is the acronym for "qualifying transitional income," which has the meaning assigned in subsection 34.2(1); "Subco" means XXXXXXXXXX, an unlimited liability company governed by the XXXXXXXXXX; and "taxable Canadian corporation" has the meaning assigned in subsection 89(1). ...
Ruling

2012 Ruling 2011-0427951R3 - Loss Consolidation

“Proposed Transactions” means the transactions described in 22 38 below; v. ...
Ruling

2014 Ruling 2014-0518521R3 - Issuance of a new class of units - Hedged Class

XXXXXXXXXX 2014-051852 XXXXXXXXXX, 2014 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX (the "Taxpayer") – BN: XXXXXXXXXX This is in response to your letter dated XXXXXXXXXX wherein you requested an advance income tax ruling on behalf of the Taxpayer. ...
Technical Interpretation - Internal

21 October 2015 Internal T.I. 2015-0592781I7 - treatment of bond locks

Frost and as evidenced by Standard & Poor's credit watch discussed above. ...
Ruling

2010 Ruling 2009-0341561R3 - Irish CCF

The Units will not have any voting rights (save the right, on written notice signed by Unitholders holding XXXXXXXXXX % of the Units, to require the Manager to resign). ...

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