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This was to be accomplished by ACo transferring its FA1 shares on a s. 85.1(3) rollover basis to a newly-formed non-resident subsidiary (New FA), with New FA then transferring its FA1 shares to BCo for a note – which then was to be repaid in cash out of share subscription proceeds from ACo, and with FA1 then distributing such cash to ACo (with a Reg. 5901(2)(b) designation being made). ... In order to satisfy a CRA requirement that the cost to BCo of the FA1 shares (which were excluded property) be limited to the sum of their relevant cost base and the net surplus (being exempt surplus) of FA1 – rather than being stepped up to their higher fair market value, the note equalled such sum. ...

[F]or each class of identical securities held by a Participating … Public Fund, [it] will transfer the Transfer Percentage of such securities to its corresponding New Fund. If and as necessary, each such Participating … Public Fund may take advantage of the provisions of subsection 107.4(2.1) of the Act to avoid the need to transfer a fractional share to its corresponding New Fund. ...

Ruling: The negative repo spread … will not be considered to be interest or an amount paid or credited as, on account or in lieu of, or in satisfaction of interest for the purposes of paragraph 212(1)(b) …. ...

Proposed transactions The shareholders of Opco will transfer their shares on a s. 85(1) rollover basis to a newly-incorporated corporation (Holdco – which had no shares issued on its incorporation by Messrs. ... Additional information The estate planning transactions … will not be carried out with a view to completing the series of transactions that includes the Proposed Transactions and would be completed notwithstanding the implementation of the Proposed Transactions, and vice versa. ... Other comments CRA has not reviewed the allocation of safe income between Opco and Realtyco but is "generally of the view that Safe Income should be allocated in a manner consistent with documents 2020-0861031C6 and 2021-0889611E5 ". ...

New structure: Common Shareholders of Newco (following the entering into of a shareholders' agreement many of whose terms are similar to the former Partnership Agreement) will have the option of providing their services personally or by using a "New Contracting Corporation" which is owned by, and is the employer of, him or her – except that preference shares may be held by family members – so that each New Contracting Corporation will provide services for agreed fees, will be responsible for specified expenses such as professional membership fees, insurance premiums, education expenses, travel expenses and entertainment expenses (with Newco to provide each New Contracting Corporation with certain supplies, facilities and equipment but with their fair market value to be borne by the New Contracting Corporation), and with the New Contracting Corporation free to compete with Newco. ...

Rulings: Each Investor's interest in the Foreign Partnership will be taxable Canadian property Such interest will be treaty-protected property for Investors resident in Foreign Countries 1 through 4 provided stipulated conditions relevant to the applicable Treaty are satisfied, as follows: Treaty 1- the only properties of the Foreign Partnership are the shares of Foreign Parent, the Foreign Parent Loans and the Foreign Subsidiary Loans Treaty 2 – the Investor does not have a controlling interest, (a controlling interest being where the Investor and persons related to the Investor have an interest of 50% or more), in the Foreign Partnership Treaty 3 – no additional conditions Treaty 4- the Investor and any persons related to or connected with the Investor are entitled to an interest of less than 10% of the income and capital of the Foreign Partnership immediately before the Disposition Time Treaty 5- not treaty-protected property ...

The Income will be added to the exempt earnings of the FA5 Subsidiary pursuant to Reg. 5907(1) – exempt earnings – s. ...

This was to be accomplished by ACo transferring its FA1 shares on a s. 85.1(3) rollover basis to a newly-formed non-resident subsidiary (New FA), with New FA then transferring its FA1 shares to BCo for a note – which then was to be repaid in cash out of share subscription proceeds from ACo, and with FA1 then distributing such cash to ACo (with a Reg. 5901(2)(b) designation being made). ... In order to satisfy a CRA requirement that the cost to BCo of the FA1 shares (which were excluded property) be limited to the sum of their relevant cost base and the net surplus (being exempt surplus) of FA1 – rather than being stepped up to their higher fair market value, the note equalled such sum. ...

Reg. 5907(5.1) will apply to the disposition by CFA2 of its capital property to CFA1 pursuant to the Proposed Business Transfer (with the summary stating): No gain or loss is recognized on the transfer of the capital assets under the relevant foreign income tax law, and the other conditions … in subsection 5907(5.1) … are met. ...

In order that Parent could get basis for having issued the share consideration, it was stated in a funding agreement to have issued such shares in consideration for the issuance to it by Merger Sub1 of common shares of Merger Sub1 – and CRA ruled that indeed those shares issued to Parent had a cost to it equal to the FMV of the shares issued by it in turn to the Target shareholders plus any related costs incurred by it. ... CRA further ruled that on the immediately subsequent contribution by Parent of its shares of Merger Sub1 to Opco, it did not realize a gain, and Opco had full cost for those shares pursuant to s. 53(1)(c) – and Opco also was able to increase the PUC of its shares in reliance on s. 84(1)(b) in an amount equal to the FMV of those contributed shares. ...