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The US Employee at all times remained on the payroll of USCo and was remunerated by USCo for the services performed during the period US Employee was in Canada; The US Employee, at all times, remained an employee of USCo and was not an employee of Canco in substance or in form; On January 1, 2009, the US Employee was granted options to purchase shares of Canco in consideration for his duties of employment performed for USCo. ... In particular, when an option to acquire shares of a public corporation is issued to a non-resident individual as consideration for employment services that are performed in Canada, the benefit received by the individual from the exercise of the option will, by virtue of section 7 and subparagraph 115(1)(a)(i), be included in the non-resident individual’s “taxable income earned in Canada” in the year in which the shares are acquired. ...

Nothing in this ruling letter should be construed as implying that the CRA has agreed to, reviewed or has made any determination in respect of any tax consequences relating to the Facts, Proposed Transactions and Additional Information described herein other than those specifically described in the ruling given above or, without limiting the generality of the foregoing, any issues concerning the validity or existence of the LPs or any issues or considerations arising from the LP Agreements; any withholding tax considerations as may be relevant for the purposes of the Proposed Transactions; availability of the functional currency elections under section 261; and the GST implications of any of the Proposed Transactions. ...

The interest payable is deemed to be an obligation having a principal amount and there will be forgiven amounts to the extent the consideration given in settlement of Loan 3 and the accrued and unpaid interest regarding Loan 3 is less than their principal amounts. 3. ... XXXXXXXXXX, Canco 2 subscribed for XXXXXXXXXX class A preferred shares of Canco 1 for a total consideration of $XXXXXXXXXX. 26. ...

Reasons: (1) The existing unitholders will not receive any cash or other consideration for the issuance of the new class of units; (2) The issuance of the new class will not result in any significant change to the fund so as to cause a resettlement of the fund. ... Existing Unitholders will not receive any financial compensation or proceeds of any kind, what so ever, as consideration for the issuance of Hedged Units, nor will Units be redeemed or cancelled as a result of the issuance of Hedged Units. 24. ...

As consideration therefor, the Estate will receive XXXXXXXXXX additional Class A shares of Newco and a non-interest bearing demand promissory note (the “Promissory Note”) having a principal amount equal to the ACB of the Remaining Shares, less $XXXXXXXXXX. ... This purpose was accomplished in the particular manner described in Paragraphs 9.1 and 11 for practical rather than tax considerations. 32. ...

3) During which period shall the Minister reassess a taxpayer in order to take into consideration a reduction of an amount otherwise required to be included in computing the deceased's income, as permitted by subsection 146.3(6.2)? 4) When does an amount need to be paid by or on behalf of a taxpayer to a carrier as consideration for a RRIF in order to be deductible under paragraph 60(l)? ...

En pareil cas, s'il est raisonnable de conclure que l'existence distincte des sociétés est motivée essentiellement par des considérations fiscales, les sociétés seront réputées associées l'une à l'autre. ... Une analyse des opérations et des états financiers des deux sociétés révélait clairement la prise en compte d'un certain nombre de considérations fiscales par M. ...

Position: (1) no (2) no (3) no Reasons: (1) The changes are not considered material or significant to result in a resettlement of the trust and it is submitted that there will be no resettlement as a matter of provincial law. (2) No cash consideration or other proceeds of disposition will be received by the unitholders in respect of the diminishment of their rights as a consequence of the amendments. ... Unitholders will not receive any financial compensation or proceeds of any kind whatever, as consideration for the issuance of the XXXXXXXXXX Preferred Units; nor will Units be redeemed or cancelled as a result of the issuance of the XXXXXXXXXX Preferred Units. 24. ...

No other consideration will be received by any holder of the Common Shares. ... Comments Nothing in this ruling letter should be construed as implying that the Canada Revenue Agency has agreed to, reviewed or has made any determination in respect of: (a) the FMV or ACB of any property or the PUC of any shares referred to herein; (b) foreign law or foreign tax considerations; or (c) any tax consequences relating to the facts and Proposed Transactions described herein other than those specifically described in the rulings given above. ...

Immediately following the payment of interest to Lossco, described in Paragraph 22, the following transactions will occur to unwind the loss consolidation arrangement: (a) Newco will redeem the Newco Preferred Shares held by A Co in consideration for a non-interest bearing promissory note issued by Newco (the "Newco Note"). ... The Newco Preferred Shares will not, at any time during the implementation of the Proposed Transactions described herein, be: (a) the subject of any undertaking that is a guarantee arrangement; (b) the subject of a dividend rental arrangement; (c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); (d) issued for consideration that is or includes: (i) an obligation of the type described in subparagraph112(2.4)(b)(i),or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii). 39. ...