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2007 Ruling 2007-0245281R3- windup of income trust on sale of assets:3rd party-- summary under Subsection 104(6) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(6) realization and distribution of target MFT gain After the acquisition of a mutual fund trust (the "Fund") by Bidco, the Fund sells all its assets, including an interest in a limited partnership, to Bidco in consideration for the assumption of liabilities and a note of Bidco. ...

2007 Ruling 2007-0245281R3- windup of income trust on sale of assets:3rd party-- summary under Subsection 80(1) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(1) In connection with the winding-up of an income fund (the "Fund") after the acquisition of all its units, the Fund disposes of its assets (principally, limited partnership units) to the acquiring corporation ("Bidco") in consideration for a note of Bidco, and then distributes the note to Bidco in satisfaction of a capital distribution and capital gains distribution declared by the Fund so that the note is extinguished as a matter of law. ...

2007 Ruling 2007-0245281R3- windup of income trust on sale of assets:3rd party-- summary under Subsection 80(5) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(5) In connection with the winding-up of an income fund (the "Fund") after the acquisition of all its units, the Fund disposes of its assets (principally, limited partnership units) to the acquiring corporation ("Bidco") in consideration for a note of Bidco, and then distributes the note to Bidco in satisfaction of a capital distribution and capital gains distribution declared by the Fund so that the note is extinguished as a matter of law. ...

25 February 2005 Ruling Case No. 56925 [discount not a device]-- summary under Coupon Summary Under Tax Topics- Excise Tax Act- Section 181- Subsection 181(1)- Coupon discount not a device An electronic discount made available by the manufacturer to all purchasers of the particular product from the retailer would not be considered to be a coupon, as the purchasers would not be in possession of any device that entitled them to a price reduction, and the retailer would not be accepting any device in full or partial consideration for the supply made by it. ...

2009 Ruling 2008-0304371R3- Single-Wing Butterfly-- summary under Subsection 20(24) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(24) portion of assets transferred to transferee corporation on butterfly treated as s. 20(24) payment In a single-wing butterfly of a company whose assets consisted of cash and cash equivalents, tenant receivables and a revenue producing rental property, the transferee corporation (B Sub Holdco) will assume various undertakings of the distributing corporation (Opco), and a joint s. 20(24) election will be made respecting the consideration paid by Opco for such assumption. ...

In connection with a takeover bid by Holdco for a public corporation in Country A, it uses the borrowed money to acquire (but not obtain a beneficial interest) in treasury shares of the taxpayer for the sole purpose of transferring such shares to the shareholders of Target as the consideration for acquiring their shares of the Target. ...

The mortgages will be sold, on a fully-serviced basis, by the Issuer for a single aggregate consideration, with respective undivided beneficial ownership interests in such pool represented by written instruments. ...

2014 Ruling 2013-0513211R3- Butterfly Transaction-- summary under Subsection 186(1) Summary Under Tax Topics- Income Tax Act- Section 186- Subsection 186(1) split-up CCPC butterfly was structured to avoid Part IV circularity In a butterfly reorganization for the split-up of DC into three TCs, the Part Iv tax circularity problem is addressed by having DC transfer its properties to respective new Subcos of each TC, so that no s. 186(1)(b) Part IV tax is generated on the redemption of the prefs received by DC as consideration. ...

2016 Ruling 2015-0571441R3- Dutch Cooperative- 93.2 & 95(2)(c)-- summary under Subsection 93.2(2) Summary Under Tax Topics- Income Tax Act- Section 93.2- Subsection 93.2(2) membership interest in Dutch cooperative ruled to be shares Before ruling that the contribution of shares of a Netherlands private limited liability company to a newly-formed Dutch cooperative (DC), in consideration for a credit to the membership accounts of the contributing foreign affiliates equal to the FMV of the contribution, was eligible for s. 95(2)(c) rollover treatment, CRA ruled that DC was a corporation for the purposes of the Act, and a non-resident corporation without share capital for purposes of s. 93.2 and that membership interests in DC will be deemed to be shares of a single class by s. 93.2(2). ...

2015 Ruling 2015-0589471R3- Earnout-- summary under Subsection 85(1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1) s. 85(1) rollover available on dirty s. 85 exchange In connection with the implementation of an earnout transaction for the purchase of Holdco common shares by a key employee, the (corporate) shareholders of Holdco (a Canadian-controlled private corporation holding Opco) first transfer a portion of their Holdco common shares to Opco in consideration for tracking preferred shares of Opco (with Opco immediately selling the purchased common shares on a five-year earnout basis to the key employee). ...