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Miscellaneous severed letter
2003 Income Tax Severed Letter 2001-011123A30 - Foreign affiliate reorg; Deemed Active Income
The above rulings are given subject to the limitations and qualifications set out in Information Circular 70-6R5 dated May 17, 2002, issued by the Canada Customs and Revenue Agency ("the CCRA") and are binding on the CCRA. ... However, provided that the legislative proposals introduced by the Department of Finance December 20, 2002 (the "Legislative Proposals") are enacted into law as currently worded, it is our opinion that proposed paragraph 95(2)(n) will apply to deem Lenderco to be a foreign affiliate of Canco 2 in respect of which Canco 2 has a qualifying interest. ... Yours truly, XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch ...
Miscellaneous severed letter
7 July 2006 Income Tax Severed Letter 2006-0177341R3 - Creation of an income trust
XXXXXXXXXX There are XXXXXXXXXX FCo XXXXXXXXXX Shares; “eligible property” has the meaning assigned by subsection 85(1.1); “ First Act ” means the Canada Business Corporations Act; “First Exchange” means XXXXXXXXXX; “forgiven amount” has the meaning assigned by subsections 80(1) and 80.01(1); “Fund Trustees” means a group of XXXXXXXXXX persons who will be elected by Unitholders in accordance with the Fund Declaration of Trust to act as trustees of New Fund, subject to the terms of the XXXXXXXXXX Agreement. ... The above rulings are given subject to the limitations and qualifications set out in Information Circular 70-6R5 dated May 17, 2002 and are binding on the Canada Revenue Agency provided that the proposed transactions are completed within six months of the date of this letter. ...