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In its summary, the Directorate stated: The proposed subject transaction conforms with the CRA's policy to not apply subsection 55(2) of the Act to internal reorganizations within a related group for loss consolidation purposes and recognizing that property retains its character on a rollover transaction between related parties is consistent with the CRA’s position in … 2014-0553731I7 that depreciable property should retain its character on wind-up. ...

Provided that … Mr. A is regarded as a tax resident of XXXXXXXXXX by virtue of Article 4(1) of the Treaty, the capital gain realized by Mr. ...

A) and the two children – following which the shares of Mr. A and of the children would be transferred on a s. 85(1) rollover basis into a holding company controlled by Mr. ...

After preliminary transactions to distribute capital dividends and eligible dividends from the companies, the trusts were then to engage in pipeline transactions in which the Aco and Bco shares were to be transferred to a ULC Newco on a s. 85(1) rollover basis in consideration for notes and nominal value preferred shares with redemption values subject to a price adjustment clause, and then convert those notes to high-PUC shares of the ULC – and only after a number of years, might ULC be amalgamated with Aco and Bco (which would have been continued to the same jurisdiction as Aco and Bco). ...

At the appropriate time, the estate would distribute the Amalco shares and the Notes (or the funds derived from their repayment) equally among the heirs – presumably on a s. 107(2) rollout basis in the case of the Amalco shares. ...

However, on the death of Daughter2, ½ of the Fund property had been distributed in accordance with the Fund terms to her issue. ...

See summary under s. 125(7) – specified partnership income. No rulings are provided on ss. 85(2) and (3). ...

Proposed transactions Former employees (and dependants where relevant) will receive under a CCAA Plan one or more payments out of the available cash pool of Canco on account of their claim for termination of coverage under the Plans in an amount equal to their pro-rata share of the aggregate settlement amount – except that claims under a Life insurance plan will be paid separately. ...

. … [T]he Charities Directorate…have advised us that… the performance of XX services by the Charity to Newco would be a business that is not a related business. ...

. … [or that the] Proposed Transactions… will have any material impact on the trading price of the shares of the capital stock of Ultimate Parentco or the value of the options held by the Optionholders. ...