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Ruling The proposed transactions by themselves will not be considered to result in any disposition or increase in interest described in any of ss. 55(3)(a)(i) to (v). ...

Ss. 55(2) and 55(2.1) should not apply to deem such deemed dividends to be capital gains, provided that such deemed dividends do not exceed the safe income on hand that could reasonably be considered to contribute to the capital gain that could be realized on a disposition at FMV, immediately before the dividend, of the Class A and Class B common shares of DC2 held by each of TC1 and TC3 at the safe income determination time for the series of transactions that includes the payment of the deemed dividends. ...

Rulings Including that the transactions will not by themselves be considered to result in any disposition of property to, or increase in interest by, an unrelated person described in any of ss. 55(3)(a)(i) to (v). ...

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

Its deferred expenses will not be considered property for these purposes. ...

In the case of the downstream mergers, regarding the shares of the parent, the parent’s shareholder was treated as the vendor thereof and, regarding the acquisition of shares of the subsidiary, there was considered to be no vendor and the purchaser was treated as being such shareholder. ...

Rulings Including that the proposed transactions will not be considered in themselves to result in a disposition or increase in interest described in any of ss. 55(3)(a)(i) to (v) and, in particular, the transaction in 1 above will not be described in s. 55(3)(a)(ii) by virtue of s. 55(3.01)(g). ...

Rulings S. 55(2) will not apply to the receipt of the First Annual Dividends, Interim Income Dividends or Second Annual Dividends, provided that their full amount does not exceed the amount of safe income on hand that could reasonably be considered to contribute to the capital gain that could be realized on a disposition at FMV, immediately before the dividend, of the shares of the corporation on which the dividend was received at the safe income determination time for the transaction, event or series of transactions that includes the receipt of the dividend. ...

Rulings The transfers from the Direct Subtrusts to Trust A in 2 will not be considered a "disposition" by virtue of s. 248(1) – disposition, (f)(v), and Trust A will be deemed, to be the same trust as, and a continuation of, each of the Direct Subtrusts by virtue of s. 248(25.1); therefore the ACB of Taxpayer's interest in Trust A will be equal to the aggregate ACB of Taxpayer's interests in the Direct Subtrusts before the transfer. 5 and 6, and 10 (and the subsequent merger in 11) will be qualifying exchanges. ...

To the extent that a portion of the capital interest to be so distributed can reasonably be considered to relate to a deemed taxable dividend received by the Trust (whether an eligible dividend or non eligible dividend), the trustees will pass a resolution for all or a portion of the balance to be distributed as an eligible dividend to the extent of eligible dividends received by the Trust in 11 and as a non-eligible dividend for any remainder, with a s. 104(19) designation to be made. ...