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Ruling summary
2012 Ruling 2011-0421261R3 - Partnership Allocation -- summary under Subsection 103(1)
BCo will transfer its business on a rollover basis to a newly formed subsidiary limited partnership (New LP) in consideration for the assumption of liabilities and the issuance of Class A units; and ACo will fund New LP from time to time in consideration for the issuance of Class B units (which are not described in the letter to have much difference from the Class A units – including equal per-unit allocations of income or loss- except as described below) at a subscription price equal to a valuation of the NAV per Class A unit and Class B unit. ...
Ruling summary
2014 Ruling 2013-0498651R3 - Single-Wing Split-up Butterfly -- summary under Distribution
. … DC owns property ("Property1") which was rezoned…. From XX to XX, XX lots of Property1 have been severed and sold. ...
Ruling summary
2013 Ruling 2013-0502921R3 - Split-Up Butterfly - Farm -- summary under Subsection 186(1)
" See more detailed summary under s. 55(1) – distribution. ...
Ruling summary
2013 Ruling 2013-0488351R3 - Conversion of a MFC to a MFT -- summary under Qualifying Exchange
2013 Ruling 2013-0488351R3- Conversion of a MFC to a MFT-- summary under Qualifying Exchange Summary Under Tax Topics- Income Tax Act- Section 132.2- Subsection 132.2(1)- Qualifying Exchange conversion of MFC to MFT and subtrust elimination The same (mutual fund corporation) taxpayer as for 2013 Ruling 2011-0395091R3 ("MFC to MFT Conversion") (immediately below) obtained essentially the same rulings for transactions which now reflected its acquisition of "Target" trust before the implementation of the merger of the taxpayer under s. 132.2 into REIT #1 (the internally-created replacement mutual fund trust) and the elimination of various subtrusts using s. 107.4 (or s. 248(1) – non-disposition) transfers and the s. 132.2 merger rules. ...
Ruling summary
2013 Ruling 2013-0488351R3 - Conversion of a MFC to a MFT -- summary under Subsection 21(1)
See detailed summary under s. 132.2(1) – qualifying exchange. ...
Ruling summary
2013 Ruling 2013-0487911R3 - Mortgage Investment Corporation -- summary under Section 253.1
. … Opco may advance funds to the LP from time to time for working capital and development… on arm's length commercial terms…. ...
Ruling summary
2015 Ruling 2014-0541951R3 - Foreign Affiliate Debt Dumping -- summary under Subsection 212.3(3)
The letter does not specify how the s. 212.3 effect of the investments made by the three CRICs (namely, the three direct or indirect partners of FA1 – or one CRIC if the partnership interests of Canco7 and Canco8 are nominal) is effectively allocated to the one or both of the QSCs. ...
Ruling summary
2015 Ruling 2015-0610391R3 - Whether 75(2) will apply to new trusts -- summary under Subsection 75(2)
Opinion S. 104(4) will not apply to the New Trusts by reason of (g) of s. 108(1) – trust. ...
Ruling summary
2017 Ruling 2016-0675881R3 - Paragraph 55(3)(a) Internal Reorganization -- summary under Paragraph 85(1)(e)
clarifications re division between beneficial and registered ownership of buildings were made in 2017-0704351R3
(Butterfly rulings typically have prorated UCC based on relative FMV – see e.g., 2014-0530961R3 and 2013-0498651R3). ...
Ruling summary
2016 Ruling 2016-0652041R3 - Loss consolidation arrangement -- summary under Paragraph 111(1)(a)
CRA also provided a s. 55(2) ruling based on a representation that the only purpose “of the dividends on Newco’s Preferred Shares … is to provide a reasonable return….” ...