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2018 Ruling 2017-0711071R3- Use of subsidiary losses & ITCs after wind-up Unedited CRA Tags Subsections 88(1) & (1.1) Principal Issues: Can losses and ITCs of a subsidiary be claimed by a parent on a winding-up as a result of a two-step loss acquisition where the loss business carried on by the subsidiary and the shares of the subsidiary are acquired in separate transactions. ...

& THIN CAPITALIZATION Unedited CRA Tags 20(1)(c) 18(4) 133 245(2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... DCO No-Par Shares $ XXXXXXXXXX? DCO Par Shares (see paragraph 31) XXXXXXXXXX? ...

2001 Ruling 2001-0077753- DIRECTORS FEES & STOCK OPTIONS Unedited CRA Tags 6(1)(c) 7 9(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ...

1999 Ruling 9907203- DSLP, PMT OF % OF PRE-LEAVE SALARY Unedited CRA Tags 6801(a) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

2006 Ruling 2005-0151001R3- Prescribed Shares / plan of arrangement Unedited CRA Tags 110(1)(d) 251(5)(b) Reg 6204(1) Reg 6204(3)(a) Principal Issues: Will the corporation that acquired the shares of the target Canadian public corporation be a "specified person" for purposes of subsection 6204(1) of the Income Tax Regulations? ...

30 November 1997 Ruling 9806133- FOREIGN PROPERTY & LOAN TO SUBSIDIARY Unedited CRA Tags 104(6) 206(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

2002 Ruling 2002-0124183- HEALTH & WELFARE TRUSTS Unedited CRA Tags 18(9) XXXXXXXXXX 104 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ...

2003 Ruling 2001-0098963- HEALTH & WELFARE TRUST Unedited CRA Tags 18(9) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ...

1999 Ruling 9904343- EXCESS CONTRIBUTIONS H & W TRUST Unedited CRA Tags 6(1)(a) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

2012 Ruling 2010-0355941R3- reverse subsidiary merger- 87(1) & 87(11) Unedited CRA Tags 87(1)(a) & 87(11)(b) Principal Issues: Whether the reverse subsidiary merger, as described below, will be considered an amalgamation in the context of subsection 87(11) within the meaning of that term in subsection 87(1) and whether, on the reverse subsidiary merger, a new corporation (Amalco) will be considered to have acquired each capital property of the subsidiary (Target) within the meaning of paragraph 87(11)(b)? ...