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Now taking under consideration the amalgamation, s. 87(2)(aa) provided that if a dividend were paid by a predecessor corporation and a portion thereof would be deemed not to be a taxable dividend by s. 129(1.2), the RDTOH of the predecessor corporation is not transferred to the amalgamated corporation. ...

At the beginning of Year 2, C and D transfer their interests in CD under s. 97(2) to another limited partnership (Master) in consideration for LP interests in Master. ...

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. ...

After noting that s. 97(2) permits a taxpayer to dispose of property on a tax-free basis to a partnership if, among other things, the taxpayer is a member of the partnership immediately following the disposition, CRA stated: [T]here would be a disposition of the initial interest if the interests in income and in capital received in consideration had rights and characteristics sufficiently different to be distinguishable from those of the initial interest. ...

…[T]aking into consideration the foreign law under which the Partnership was formed, the provisions of the partnership agreement and the terms and conditions of the loan agreement between the Partnership and the U.S. lender, the CRA came to the conclusion that the partners of the Partnership were considered to be the payers of the interest on the Loan. ...

Among the rights that would require consideration in determining the differences, would be the right to the issued and paid-up capital respecting a share of one class as compared to that for another class. ...

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. ...