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Ruling summary

2013 Ruling 2013-0487911R3 - Mortgage Investment Corporation -- summary under Subsection 130.1(6)

. Opco may advance funds to the LP from time to time for working capital and development… on arm's length commercial terms…. ...
Ruling summary

15 March 2012 Ruling 132880-2 -- summary under Paragraph (l)

" Ruling that the Dealer's Fee received by the Dealer either as a lump-sum payment or as periodic payments for facilitating the initial sale of the […] Shares to the Client, is consideration for an exempt supply of arranging for a financial service under paragraph (l) of the definition of financial service in subsection 123(1). However, if at any time after the initial sale, the Dealer "services" the Client's account in order to earn the Dealer's Fee, or if the fee is paid to a Dealer who did not facilitate the initial sale of the […] Shares, the supply of the services for which the Dealer's Fee is paid may be considered the provision of a taxable supply. ... [T]o "service" a Client's account includes, but is not limited to: regularly contacting the Client after the initial sale to review the status of the account and the appropriateness of the […] Shares held in the account in light of the Client's financial needs and investment objectives (e.g., holding the Client invested in those Shares, performing research and analysis); offer advice by recommending any appropriate change in the account; and provide assistance to the Client by answering any questions the Client may have regarding the […] Shares and on exercising any right or privilege connected to those Shares or to the account ...

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