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Proposed transactions Although redacted, apparently Trust is amending its Unit terms to make them non-retractable and is eliminating the Special Voting Units from what it is authorized to issue – as well as authorizing the issuance of the Preferred Units. ...

Y could generally be allowed …. ...

2014 Ruling 2014-0518451R3- Loss consolidation-- summary under Paragraph 111(1)(a) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(1)- Paragraph 111(1)(a) losses transferred to new "Aco" which is wound-up into profitco – but borrowing capacity rep of Lossco not Aco/ provincial GAAR ruling/ cashless un-wind Overview Loan 2 (in step 3 below) is being made by Lossco (the wholly-owned loss subsidiary of Parent) to Aco (so as to generate losses in Aco for later transfer under s. 88(1.1) to Opco), instead of being made directly to Opco, "to ensure that Opco, which is a public corporation, does not incur debt in order to implement the loss utilization. ...

. … [The] trust structures designed to purposely invoke attribution pursuant to subsection 75(2), with a view to avoiding the payment of tax on extracted corporate dividends …typically involves two Canadian corporations and a trust that acquires shares in one of the corporations ("Corp A"). ...

. … Our conclusion would be the same if the transactions respecting a freeze of Opco in order to introduce Nephew were part of the series of transactions that included the deemed dividend received by Holdco as a result of the redemption of the Class "D" shares of the capital stock of Opco held by Holdco, as Nephew and Nephew Inc. were related to Holdco, the dividend recipient, by virtue of subparagraphs 251(2)(b)(iii) and 251(2)(c)(ii), respectively. ...

. … Justice L'Heureux-Dubé seemed to suggest that Mara Properties stands for the proposition that subsection 88(1) deems the parent to have received property of the same character from its subsidiary upon the subsidiary's wind-up. ...

Proposed transactions The terms of the Notes A will be amended (but with no novation) to change the governing law and to add a right allowing the holder to exchange them for new Canadian-dollar interest-bearing demand notes ("Notes B"); and a similar exchange right into Canco1 Note B will be added to Canco1 Note A – with both exchange rights then being exercised by Canco3. ...

. … If the total of all the decreases exceeds the total of all the increases to the UCC of a class as of the end of a taxation year, subsection 13(1) provides that this excess shall be included in computing the taxpayer's income for the year. ...

(a)(i) of the "earnings" definition) – without duplication of the adjustments in 1 and 2. ...

. … [T]these entities have many characteristics in common with "limited liability companies" ("LLCs") that exist in the U.S., which are generally considered to be corporations for the purposes of the Act, but that they also have many characteristics in common with the various forms of partnerships.... ...