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2006 Ruling 2004-0106101R3- Class of German Arrangement & Treaty Benefits-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Ruling that a German open-end real estate fund would be treated as a resident of Germany for purposes of Article 4 of the German Treaty. ...

2013 Ruling 2013-0488661R3- Indian Band-Public Body & Function of Government-- summary under Paragraph 149(1)(c) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(c) Indian band An Indian Band governed by an elected chief and band council, which provides a wide range of listed health, social, educational and economic services to its members, is ruled to be a public body performing a function of government in Canada within the meaning of s. 149(1)(c). ...

2006 Ruling 2005-0151001R3- Prescribed Shares / plan of arrangement-- summary under Subsection 6204(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 6204- Subsection 6204(3) where pursuant to an arrangement agreement that is implemented under a plan of arrangement, employee stock options previously granted by the "Target" are transferred by the employees to Target in exchange for cash amounts equal to their in-the-money value before the acquisition pursuant to the agreement and plan by the purchaser of 100% of the shares of Target for cash consideration, such purchaser will not be a "specified person" at the time the options are so transferred. ...

2006 Ruling 2004-0106101R3- Class of German Arrangement & Treaty Benefits-- summary under Subsection 104(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(1) German real estate investment fund treated as trust Ruling that an open-end real estate fund established under the Investment Companies Act (Germany) (and to be continued under the Investment Act (Germany)) would be treated as an inter vivos trust that was not a personal trust for purposes of the Act in respect of its proposed investments in a Canadian partnership. ...

2016 Ruling 2015-0571441R3- Dutch Cooperative- 93.2 & 95(2)(c)-- summary under Subsection 93.2(2) Summary Under Tax Topics- Income Tax Act- Section 93.2- Subsection 93.2(2) membership interest in Dutch cooperative ruled to be shares Before ruling that the contribution of shares of a Netherlands private limited liability company to a newly-formed Dutch cooperative (DC), in consideration for a credit to the membership accounts of the contributing foreign affiliates equal to the FMV of the contribution, was eligible for s. 95(2)(c) rollover treatment, CRA ruled that DC was a corporation for the purposes of the Act, and a non-resident corporation without share capital for purposes of s. 93.2 and that membership interests in DC will be deemed to be shares of a single class by s. 93.2(2). ...

2016 Ruling 2015-0571441R3- Dutch Cooperative- 93.2 & 95(2)(c)-- summary under Subsection 85.1(3) Summary Under Tax Topics- Income Tax Act- Section 85.1- Subsection 85.1(3) joint contribution of shares of FA to Netherlands co-op in consideration for credits to their respective membership accounts deemed to be for share consideration Ruling respecting the combined operation of s. 95(2)(c) (similar in this regard to s. 85.1(3)) and s. 93.2) on a joint contribution by the three foreign affiliate shareholders of a foreign affiliate of their respective shareholdings to a Dutch co-operative (with membership interests rather than share capital) in consideration for credits to their respective membership interest accounts. ...

2001 Ruling 2001-0077753- DIRECTORS FEES & STOCK OPTIONS-- summary under Paragraph 7(1)(a) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1)- Paragraph 7(1)(a) options received on behalf of partnership Confirmation that where employees of the general manager of two partnerships sit on the board of directors of corporations on behalf of their employer, they are not required to report directors' fees and stock options paid to them as directors of the company. ...

1999 Ruling 9903543- TOTAL RETURN SWAPS & MUTUAL FUND TRUST-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 9- Timing An open-end unit trust invests the proceeds of a public offering in a note of a bank and then enters into a total-return swap with the Bank respecting a bond index (some of the components of which correspond to bonds held by the bank). ...

2012 Ruling 2011-0429961R3- Hydrocarbon & Immovable property: Canada-UK Treaty-- summary under Subsection 116(6.1) Summary Under Tax Topics- Income Tax Act- Section 116- Subsection 116(6.1) Ruling that the transfer of shares of a UK company (Forco2) by two other UK companies (Forco1 and Forco4) would be exempt under Art. ...

2012 Ruling 2011-0429961R3- Hydrocarbon & Immovable property: Canada-UK Treaty-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 storage business carried on in leased real estate had over 50% of value Ruling that the transfer of shares of a UK company (Forco2- whose value is derived from CAnco shares) by two other UK companies (Forco1 and Forco4) would be exempt under Art. ...