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2014 Ruling 2014-0530961R3- Cross-Border Butterfly-- summary under Subsection 86.1(2) Summary Under Tax Topics- Income Tax Act- Section 86.1- Subsection 86.1(2) spin-off by U.S. pubco of U.S. spinco after Canadian butterfly In connection with a spin-off by a U.S. public company (Foreign PubCo) of a U.S. subsidiary (Foreign Spinco) to which one of its businesses was transferred, there was a butterfly split-up of an indirect Canadian subsidiary (DC) directly and indirectly holding Canadian portions of the two businesses in question, so that the Canadian transferee corporation (TCo) of DC was a subsidiary of Foreign Spinco. In connection with the subsequent spin-off by Foreign Pubco of Foreign Spinco, CRA ruled that provided that all of the conditions of ss. 86.1(2)(e) and (f) were met, the spin-off was an eligible distribution for purposes of s. 86.1. ...

17 May 2012 Ruling 62492 [merchant Interac services]-- summary under Subsection 4(2) Summary Under Tax Topics- Excise Tax Act- Regulations- Financial Services (GST/HST) Regulations- Subsection 4(2) merchant Interac services An "Acquirer" is a connection service provider (i.e., it provides connection to the Interac network for the purpose of processing Interac direct payment transactions) and a settlement agent (i.e., the Acquirer uses the services of a bank to provide funds). ...

2014 Ruling 2014-0530961R3- Cross-Border Butterfly-- summary under Subparagraph 55(3.1)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(3.1)- Paragraph 55(3.1)(b)- Subparagraph 55(3.1)(b)(i) pro rata allocation of Foreign Spinco debt In connection with a spin-off by a U.S. public company (Foreign PubCo) of a U.S. subsidiary (Foreign Spinco) to which one of its businesses was transferred, there was a butterfly split-up of an indirect Canadian subsidiary (DC) directly and indirectly holding Canadian portions of the two businesses in question, so that the Canadian transferee corporation (TCo) of DC was a subsidiary of Foreign Spinco. ... In connection with the s. 55(3.1)(b)(i)(A)(II) rule, CRA indicated that indebtedness of Foreign SpinCo will be considered to reduce the FMV of each property of Foreign SpinCo pro rata in proportion to the relative FMV of all property of Foreign SpinCo. ...

SubCo will, by written resolution of its directors, commence proceedings for its winding-up and in connection therewith all of its property and liabilities (including its shares of NewCo2 and its partnership interest in Partnership C) will be distributed to and assumed by ParentCo, effective the date of such resolution. ... Immediately thereafter ParentCo will carry on alone the business that was the business of Partnership C and, in connection therewith, receive income from former Partnership C property and receive its share of partnership distributions from Partnership D. ... Immediately thereafter ParentCo will carry on alone the business that was the business of Partnership D and, in connection therewith, receive income from former Partnership D property and receive its share of partnership distributions from Partnership D. ...

17 May 2012 Ruling 62492-- summary under Paragraph (l) Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Financial Service- Paragraph (l) supply of continuous interac processing services is exempt An "Acquirer" is a connection service provider (i.e., it provides connection to the Interac network for the purpose of processing Interac direct payment transactions) and a settlement agent (i.e., the Acquirer uses the services of a bank to provide funds). ...

They can only be issued in connection with the issuance of Exchangeable Securities, and none currently are outstanding. ... Limited Partnership is the sole shareholder of USCo, which has issued preferred shares in connection with electing to be a [REIT]. ...

2015 Ruling 2015-0604051R3- Internal Reorganization-- summary under Subsection 212.3(2) Summary Under Tax Topics- Income Tax Act- Section 212.3- Subsection 212.3(2) extensive reps required re series of transactions In connection with a s. 55(3)(a) distribution of a Canadian subsidiary (Canco3) to a sister chain of companies held by U.S. parents, s. 212.3(2) rulings were granted based on very extensive representations about arm’s transactions not occurring as part of or before the series. ...

2000 Ruling 9929203- FOREIGN TAX CREDIT- FOREIGN ELECTION-- summary under Business-Income Tax Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(7)- Business-Income Tax U.S. tax paid by a Canadian corporation as a consequence of an s. 338(g) election and in connection with transactions under which it is acquired by a U.S. purchaser and continued as a U.S. corporation generally will be eligible for a foreign tax credit. ...

2014 Ruling 2013-0505431R3- XXXXXXXXXX-- summary under Subsection 88(1) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1) delay in filing articles of dissolution In connection with an extensive reorganization, a wholly-owned subsidiary of Pubco (Newco 2) will be wound-up into Pubco. ...

2014 Ruling 2013-0505431R3- XXXXXXXXXX-- summary under Subsection 97(2) Summary Under Tax Topics- Income Tax Act- Section 97- Subsection 97(2) s. 97(2) applicable to contribution (no equity consideration) In connection with an extensive reorganization, Pubco will transfer its undivided interest in a royalty to a partnership (Partnership D) mostly owned by it as a contribution to its capital, with a s. 97(2) election being made. ...