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For the purposes of Part XIII withholding and section 116, any amount paid or credited by a payer to the Canadian Sub-custodian in respect of the property held by the Subfund on behalf of the Pension Fund, including purchase consideration for such property, will be considered an amount paid or credited to the Pension Fund in proportion to its participation in the assets and income of the particular Subfund. ...

Rulings The reallocation of the properties in Fund 1 to Fund 2 will result in Fund 1 ceasing to exist and Fund 2 as continuing to exist for s. 138.1(1)(a) purposes and be considered to be a transfer by Trust 1 of all of its property to Trust 2 for the purpose of s. 107.4, with s. 107.4(3)(j) applying to deem each of the Fund 1 Policyholders to have disposed of their capital interests in Trust 1 for proceeds equal to the cost amount of such capital interests immediately before the disposition and to have acquired capital interests in Trust 2 at a cost equal to the amount determined by subparagraph 107.4(3)(j)(ii). ...

Rulings No portion of the cash or near cash investments distributed by Opco to Holdco, or by Holdco to Parent, will be considered to be subject property of an RCA for the purposes s. 207.6(1), or a “contribution” made to an RCA, in respect of the SERP Obligations that will be assumed by Parent. ...

For the purposes of Part XIII and s. 116, any amount paid or credited by a payer to the sub-custodians in respect of property held by a Sub-Fund on behalf of the New Investors, including purchase consideration for such property, will be considered an amount paid or credited to the New Investor in proportion to its co-ownership interest in the assets and Gross Income of the particular Sub-Fund. ...

Ruling ForCo will not be considered to be carrying on business through a permanent establishment, as defined in Art. ...

For the purposes of Part XIII and s. 116, any amount paid by a person to the Sub-custodian respecting Sub-fund Canadian securities will be considered to arise at the time of payment and to have the same character and source in respect of each Unitholder thereunder in proportion to the number of Units held by that Unitholder that represents its participation in such property. ...

Rulings Include that the Proposed Transactions will not by themselves be considered to result in a disposition or increase in interest described in subparagraphs 55(3)(a)(i) to (v). ...

For [such] purposes … the capital of Amalco attributable to the Bco-Newco Note and the XXXXXXXXXX of common shares of the capital stock of Amalco of $XXXXXXXXXX will be considered to be used by Amalco for eligible purposes for the purposes of subparagraph 20(1)(c)(i) provided that the property that will become property of Amalco on the amalgamation of Newco and Cco or the property that will be substituted therefor will be used and will continue to be used by Amalco for the purpose of gaining or producing income from its business. ...

The Partnership activity was carried on in common with a view to a profit and the Partnership was considered a partnership for purposes of the Act prior to the Proposed Transaction. ...

Pursuant to ss. 88(2)(b)(i) and 83(2), a portion of the winding-up dividend may be considered as a separate dividend paid out of the CDA of DC. ...