Search - connection

The share certificates in connection with the various share transactions outlined above will be handled as set forth below. ... (c) From and after the time of the exchange described in Paragraph 61, share certificates representing Existing PUBCO/XXXXXXXXXX Shares held by a Participant shall for all purposes be deemed to be shares certificates representing New PUBCO/XXXXXXXXXX Shares, and no new share certificates shall be issued with respect to the New PUBCO/XXXXXXXXXX Shares issued in connection with the Arrangement. (d) From the time of the exchange described in Paragraph 61, to the close of business on the record date described in subparagraph (b) hereof, share certificates representing Existing PUBCO/XXXXXXXXXX Shares held by a Participant also shall be deemed pursuant to the Plan of Arrangement for all purposes also to represent NewCo Shares until the time of the Amalgamation and thereafter to represent AmalCo Shares issued in connection with the Plan of Arrangement. ...

We acknowledge receipt of your letters of XXXXXXXXXX and our telephone conversations in connection herewith. ... In connection with the transfer of properties described in paragraph 33, XXXXXXXXXX/A and XXXXXXXXXX/Cco will jointly elect in prescribed form within the time limit referred to in subsection 85(6), to have the provisions of subsection 85(1) apply to the transfer of each property of XXXXXXXXXX/A that is an eligible property transferred to XXXXXXXXXX/Cco. ... In connection with the transfer of properties described in paragraph 36, XXXXXXXXXX/Cco and XXXXXXXXXX/Aco will jointly elect in prescribed form within the time limit referred to in subsection 85(6), to have the provisions of subsection 85(1) apply to the transfer of each property of XXXXXXXXXX/Cco that is an eligible property transferred to XXXXXXXXXX/Aco. ...

We understand that to the best of your knowledge and that of each of the Taxpayers involved, none of the issues described herein are: (a) in a previously filed tax return of the Taxpayers or person related to the Taxpayers; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the Taxpayers or a person related to the Taxpayers; (c) under objection by the Taxpayers or a person related to the Taxpayers; (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; and (e) the subject of an advance income tax ruling previously issued by the Income Tax Rulings Directorate of the CRA in connection with the Taxpayers or a person related to the Taxpayers. ... The agreed amount in respect of each such eligible property will be as follows: a. in the case of capital property (other than depreciable property of a prescribed class), an amount equal to the lesser of the amounts described in subparagraphs 85(1)(c.1)(i) and (ii); b. in the case of depreciable property of a prescribed class, if any, an amount not less than the least of the amounts described in subparagraphs 85(1)(e)(i), (ii) and (iii); and c. in the case of inventory owned in connection with the XXXXXXXXXX business of DC, an amount determined in accordance with the formula set out in paragraph 85(1)(c.2). ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

In connection with the winding-up, the TC Sub1 Redemption Note will be assumed by TC1, the TC Sub2 Redemption Note will be assumed by TC2 and the TC Sub3 Redemption Note will be assumed by TC3. 29. ... In connection with the winding-up of DC, DC will distribute all of its assets, which will consist only of TC Sub1 Redemption Note, TC Sub2 Redemption Note and the TC Sub3 Redemption Note and the rights to any tax refunds referred to in Paragraph 34, to TC1, TC2 and TC3, as the case may be, in accordance with their respective shareholdings. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover Yours truly, XXXXXXXXXX For Division Director Reorganizations Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Answer In determining whether a property is a tax shelter for the purposes of section 237.1 of the Act, the calculation of deductible losses and other deductible amounts is to be made on a prospective basis based upon statements or representations made or proposed to be made in connection with that property. ... Is it the government's intention to force all related companies, regardless of their inter-connection of business interests, to come to an agreement on how to allocate the capital deduction, or is it possible that a more reasonable middle ground could be reached by ensuring all associated corporations must allocate the deduction? ... The Queen 83 DTC 5041, when he described the expression as "probably the widest of any expression intended to convey some connection between two related subject matters".  ...

Answer In determining whether a property is a tax shelter for the purposes of section 237.1 of the Act, the calculation of deductible losses and other deductible amounts is to be made on a prospective basis based upon statements or representations made or proposed to be made in connection with that property. ... Is it the government's intention to force all related companies, regardless of, their inter-connection of business interests, to come to an agreement on how to allocate the capital deduction, or is it possible that a more reasonable middle ground could be reached by ensuring all associated corporations must allocate the deduction? ... The Queen [[1983] C.T.C. 20] 83 DTC 5041, when he described the expression as "probably the widest of any expression intended to convey some connection between two related subject matters". ...

To the best of your knowledge and that of the Taxpayers involved, none of the Proposed Transactions (as defined below) or the issues involved in this Ruling request are the same as or substantially similar to transactions or issues that are: (i) in a previously filed tax return of any of the Taxpayers or a related person and: A. being considered by the CRA in connection with such return; B. under objection by any of the Taxpayers or a related person; or C. the subject of a current or completed court process involving any of the Taxpayers or a related person; or (ii) the subject of a Ruling request previously considered by the Income Tax Rulings Directorate. ... All properties of TC Sub1 and TC Sub2 will be distributed and all liabilities of TC Sub1 and TC Sub2, if any, will be either discharged or assumed by its TC. ln connection with the winding-up, the TC Sub1 Redemption Note will be assumed by TC1 and the TC Sub2 Redemption Note will be assumed by TC2. 42. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...