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The ruling was conditioned on the new options of Spinco and New DC being the sole consideration for the disposition of the old options and the old options being cancelled. ...

The purpose of having Target survive the merger under the plan of arrangement was to allow for an exchange of Target shares for shares of Acquireco to qualify as a reorganization for US income tax purposes for US shareholders of Target, although at the end of the day the Target shareholders received cash consideration from Acquireco instead. ...

The purpose of having Target survive the merger under the plan of arrangement was to allow for an exchange of Target shares for shares of Acquireco to qualify as a reorganization for US income tax purposes for US shareholders of Target, although at the end of the day the Target shareholders received cash consideration from Acquireco instead. ...

Ruling that the rebate is consideration for a taxable supply. CRA stated: [T]he Company's activities when considered as a whole are predominantly promoting and marketing the [credit card] program….Moreover, the services performed by the Company do not meet the factors that are used to determine whether a supply is arranging for a financial service under paragraph (l), such as the degree of direct involvement with the consumers or the time expended by the Company in the provision of a financial service referred to in any of paragraphs (a) to (i). ...

After giving favourable s. 111(5)(a) rulings, CRA ruled that s. 245(2) will apply on the basis "that the repayment of the subordinated debt...will be considered a settlement of the subordinated debt for no consideration for the purposes of applying section 80. ...

2004 Ruling 2003-0053981R3- XXXXXXXXXX-- summary under Paragraph 107.4(1)(a) Summary Under Tax Topics- Income Tax Act- 101-110- Section 107.4- Subsection 107.4(1)- Paragraph 107.4(1)(a) qualifying drop-down of partnership units to subsidiary unit trust where s. 107.4(2)(a) was ousted due to units issuance Proposed transactions The Fund, which is an exchange-traded mutual fund trust, will for nominal consideration subscribe for one Trust Unit of a unit trust (the “Trust”) that was settled by a third party, and redeem the initial Trust Unit held by that third party for its cash subscription price. ...

(h) A publicly-trade mutual fund trust (the "Fund") eliminated a corporate subsidiary ("Holdings") by incorporating a subsidiary ("MFC") with a modest value, distributing interests in MFC to its unitholders as a capital distribution in order that MFC would qualify as a mutual fund corporation, transferring Holdings to MFC on a s. 85(1) rollover basis in consideration for MFC shares, having MFC amalgamate with Holdings to form MFC Amalco, and then having MFC Amalco merge into the Fund in accordance with s. 132.2 so that the Fund acquired the assets of MFC Amalco, principally, units in a subsidiary LP. ...

2004 Ruling 2003-0053981R3- XXXXXXXXXX-- summary under Paragraph 107.4(3)(m) Summary Under Tax Topics- Income Tax Act- 101-110- Section 107.4- Subsection 107.4(3)- Paragraph 107.4(3)(m) units must be received on drop-down of LP to new subtrust (thereby ousting s. 107.4(2)(a)), in order to receive outside basis under s. 107.4(3)(m) The Fund, which is an exchange-traded mutual fund trust, will for nominal consideration subscribe for one Trust Unit of a unit trust (the “Trust”) that was settled by a third party, and redeem the initial Trust Unit held by that third party for its cash subscription price. ...

BForHoldco then transfers its B shares to Opco in consideration for the issue of shares of a new class of common shares of Opco (with this "tuck-under" transaction not being ruled on), Aco effects a simultaneous s. 86 exchange of its shares in Opco (so as to preclude the tuck-under transaction giving rise to an acquisition of control of Opco by Aco), and BCo and Opco then amalgamate by way of a vertical short-form amalgamation. ...

BForHoldco then transfers its B shares to Opco in consideration for the issue of shares of a new class of common shares of Opco (with this "tuck-under" transaction not being ruled on), Aco effects a simultaneous s. 86 exchange of its shares in Opco (so as to preclude the tuck-under transaction giving rise to an acquisition of control of Opco by Aco), and BCo and Opco then amalgamate by way of a vertical short-form amalgamation. ...