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2021 Ruling 2020-0868661R3 F- Section 84.1 – Leveraged Buyout-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) ruling that buyout was an arm’s length transaction The shares of Holdco- which holds real estate that it leases to Opco (carrying on a Canadian active business) – are held by three unrelated individuals: Mr. ... X and [Newco] are dealing with each other at arm’s length” – and the body of the ruling letter noted that representations were submitted to this effect. ...

6 June 2014 Ruling 143085 [loaner vehicles are provided as part of a single supply of repair services – no RITC]-- summary under Paragraph 28(1)(d) Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations, No. 2- Paragraph 28(1)(d) loaner vehicles are provided as part of a single supply of repair services – no RITC Corp A, which is a large business per s. 236.01, and s. 27 of the New Harmonized Value-Added Tax System Regulations, No.2 (the Regulations), sells and leases vehicles through its Dealership), reimburses the Dealerships for basic warranty repair services, and repairs performed under "Service Contracts," and reimburses Dealerships for providing loaner cars (from the Dealership's lot or, failing that, from a car rental agency) for their basic warranty customers whose vehicles cannot be driven and must be kept at the Dealership overnight. ... The charge in respect of a loaner vehicle under either the basic warranty coverage or Service Contract is part of the consideration for the supply of the repair service. … ...

2018 Ruling 2018-0740931R3 F- deductibility of interest – convertible debentures-- summary under Subsection 20(3) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(3) s. 20(3) applicable to borrowed money used to redeem principal of convertible debentures A Canadian public company (ACo) will force the conversion of its outstanding convertible debentures, by issuing a notice to redeem them for their principal amount. ... It also ruled: Subsection 20(3) will be applicable to the portion of Loan 3 … corresponding to the aggregate principal amount of the outstanding Debentures … such that borrowed money will be deemed for purposes of the application of paragraph 20(1)(c) to be used for the purposes for which the outstanding Debentures were used or incurred. ...

2021 Ruling 2021-0911211R3- Foreign Takeover-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt borrowing and payment of funds pursuant to an internal payment direction agreement CRA ruled on transactions which included the borrowing of money by a newly-formed non-resident corporation (Merger Sub1) from a Canadian affiliate (Opco) and its advance of such funds to a transfer agent for shareholders of a non-resident target (Target), pursuant to directions in an internal funding agreement. ...

2023 Ruling 2023-0973911R3- Loss Consolidation Ruling-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt daylight loan circled 4 times CRA ruled on a triangular loss-shifting transaction between Lossco and its subsidiary, Profitco, under which Lossco used a daylight loan to make an interest-bearing loan (pursuant to the “IB Note”) to Profitco, who subscribed for preferred shares of its sister, “Numberco,” who made a non-interest-bearing loan to Lossco. ...

2021 Ruling 2021-0876671R3- Transfer between US pension plans-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt no constructive receipt to Canadian beneficiaries where the transfer of a portion of the assets and Canadian beneficiaries from an old to a new US pension plan S. 56(1)(a) generally requires the recognition of an amount received as or in satisfaction of a pension benefit. ...

2023 Ruling 2023-0964601R3- Loss consolidation arrangement-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt in-house re-circulating daylight loan used to fund a loss-shifting transaction CRA ruled on routine transactions between two Lossco subsidiaries and one Profitco subsidiary of an immediate Canadian parent company involving Lossco loans to the Profitco and Profitco subscriptions for Lossco cumulative preferred shares. ...

2018 Ruling 2018-0740931R3 F- deductibility of interest – convertible debentures-- summary under Subparagraph 20(1)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) interest on borrowed money used to pay a premium on the cash redemption of convertible debentures is deductible Proposed transactions ACo, a listed Canadian public company, whose outstanding convertible debentures (the “Debentures”) are about to mature, will borrow from a lender (BCo) under “Loan 3.” ... However, upon receiving the notices of redemption for the Debentures, ACo will have the right to redeem such Debentures for an amount corresponding to the market value of the ACo shares into which they are convertible – which it will do, using proceeds of Loan 3 and thereby paying a “Conversion Premium C” over the redeemed Debentures’ principal amount. ...

2004 Ruling 2004-0099651R3- Migration to Canada / PUC Reduction-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) Opinion that a non-resident corporation would become resident in Canada upon replacing its board with a new board a majority of whom resided in Canada and which conducted meetings in Canada. ...

2004 Ruling 2004-0099651R3- Migration to Canada / PUC Reduction-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) Opinion that a non-resident corporation would become resident in Canada upon replacing its board with a new board a majority of whom resided in Canada and which conducted meetings in Canada. ...