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14 June 2002 External T.I. 2001-0103755 F- Cumulative Eligible Capital on Amalgamation-- summary under Paragraph 87(2)(f) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(2)- Paragraph 87(2)(f) Amalco should not have 2 CEC adjustment times In Situation 1, Portfolioco and its wholly-owned subsidiary, Subco, which were both incorporated on February 1, 1993, amalgamated on July 1, 2001 to form Amalco and each had a positive CEC balance immediately before the amalgamation. ... Calculating the CEC on the basis that Amalco would have an adjustment time of June 30, 2001 would result in inappropriate and unfavourable tax consequences for corporations resulting from an amalgamation. … In our opinion, for the purposes of calculating the CEC of Amalco in Situations 1 and 2 described above, it should be considered that there is a continuation of the calculation of the CEC of Portfolioco and Subco in Amalco. ...

6 August 2002 External T.I. 2002-0130735 F- DISPOSITION D'UN PERMIS-- summary under Class 14 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 14 licence to operate a seniors home was eligible capital property whereas related agreements with Ministry (that after a point were not automatically renewable) were Class 14 property A corporation operated, under lease, a residential and long-term care centre pursuant to (i) a licence issued by the Quebec Ministry of Health and Social Services licences the operation of a specific number of beds at a specific location, and (ii) an operating contract and a facility use contract with the Regional Board and the Minister for a term of 13 years, including an automatic five-year renewal period, with there being no guarantee of renewal thereafter. ... Nonetheless, if the licence was attached to a specific facility and ceased to be valid when the establishment was no longer operated in that facility, it would have a time-limited duration – but that was not the case here as the licence would continue to be valid upon a change, approved by the Regional Board, in the location of the facility, so that it appeared that the licence had an open-ended duration and would be ECP. ...

12 December 2002 External T.I. 2001-0100755 F- Impact of LCB on Dr and Part IV-- summary under Paragraph 186(1)(b) Summary Under Tax Topics- Income Tax Act- Section 186- Subsection 186(1)- Paragraph 186(1)(b) connected dividend recipient is not required to pay s. 186(1)(b) tax if it can demonstrate by the return-filing deadline that such tax was eliminated through a loss carryback During its the taxation year ending September 30, 2000 ("2000 TY”), Bco paid its CCPC parent (Aco) a taxable dividend of $223,500, entitling it to a dividend refund ("DR") of $74,500, which reduced its total taxes payable for the year (otherwise $100,000 of Part I tax, payable on taxable capital gains) to $25,500. ... In addition, the CCRA could pay Aco interest on the amount refunded at the prescribed rate … for a particular period determined under subsections 164(3) and 187(3)... ...

12 December 2002 External T.I. 2001-0100755 F- Impact of LCB on Dr and Part IV-- summary under Subsection 164(1) Summary Under Tax Topics- Income Tax Act- Section 164- Subsection 164(1) where subsequent loss carryback eliminates the Part I tax and dividend refund (DR), the refund interest is calculated on the initial Part I tax amount even if the DR reversal is paid by set-off During its the taxation year ending September 30, 2000 ("2000 TY”), Bco paid its CCPC parent (Aco) a taxable dividend of $223,500, entitling it to a dividend refund ("DR") of $74,500, which reduced its total taxes payable for the year (otherwise $100,000 of Part I tax, payable on taxable capital gains) to $25,500. ... The amount of interest on the "overpayment" would be calculated at the prescribed rate … for the period from the latest of the days referred to in paragraphs 164(3)(a) to (e), taking into account paragraph 164(5)(d), to the day on which the amount is refunded or applied. ...

2002 Ruling 2001-0093903- German Organschaft-- summary under Clause 95(2)(a)(ii)(B) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(ii)- Clause 95(2)(a)(ii)(B) application of s. 95(2)(a)(ii)(B) to profit transfer payments made by German subs to German parent under an Organschaft Background Canco, a Canadian public company, holds all the shares of a German Gesellschaft mit beschränkter Haftung (“FA Holdco”) which, in turn, holds shares of two controlled foreign affiliates ("FA Opco1," and “FA Opco2”), each of which is a German Gesellschaft mit beschränkter Haftung, as well as interest-bearing debt of FA Opco1 and FA Opco2 (the "FA Opco1 Debt" and “FA Opco2 Debt”), with the balance of the shares of FA Opco1 and 2 held by unrelated German companies. ... Proposed transactions FA Holdco will acquire the XX % interest in FA Opco1 held by the unrelated German companies. ...

15 April 2002 External T.I. 2002-0128145 F- 84.1(2)(a.1) of the Act-- summary under Subparagraph 84.1(2)(a.1)(ii) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2)- Paragraph 84.1(2)(a.1)- Subparagraph 84.1(2)(a.1)(ii) where old common exchanged for new common shares and prefs with s. 85(1) election equal to the pref FMV, the s. 110.6 deduction will be traced under s. 84.1(2)(a.1)(ii) only to the prefs Mr. ... X of the preferred shares would be attributable to the capital gains deduction – so that there would be a deemed dividend of $500,000 paid by Cco to Mr. ...