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Ruling

2017 Ruling 2016-0680261R3 - Loss consolidation arrangement

At the time of the Proposed Transactions, Lossco will have the borrowing capacity to obtain a daylight loan, in an amount equal to the amount of Loan 1, directly from an arm’s length XXXXXXXXXX and this borrowing will not cause Lossco to contravene its debt covenants. ...
Ruling

30 November 1996 Ruling 9724523 - PHANTOM STOCK PLAN

(i) In the event of a stock dividend, stock split, combination or exchange of shares, merger, consolidation, spin-off or other distribution (other than normal cash dividends) of XXXXXXXXXX assets to shareholders, or any other change affecting the XXXXXXXXXX Common Shares, such proportionate adjustments, if any, as the HRC in its discretion may deem appropriate to reflect such change, will be made with respect to the number of Units outstanding under the DSUP, provided such proportionate adjustment does not contravene the condition in paragraph 8(r) below. ...
Technical Interpretation - Internal

28 April 2003 Internal T.I. 2003-0007327 - Barbados SRL

Other features of Part VII of the SRL Act are also similar to the IBC Act, for example, an International/Exempt SRL is subject to similar trading restrictions as an IBC and both types of entities could lose their licence and special tax benefit if they contravene such trading restrictions. ...
Technical Interpretation - Internal

28 April 2003 Internal T.I. 2003-0007347 - Barbados SRL

Other features of Part VII of the SRL Act are also similar to the IBC Act, for example, an International/Exempt SRL is subject to similar trading restrictions as an IBC and both types of entities could lose their licence and special tax benefit if they contravene such trading restrictions. ...
Ruling

2018 Ruling 2018-0741691R3 - Loss consolidation arrangement

At the time of the Proposed Transactions, Lossco will have the borrowing capacity to obtain a daylight loan, in an amount equal to the amount of Loan 1, directly from an arm’s length XXXXXXXXXX and this borrowing will not cause Lossco to contravene its debt covenants. ...
Ruling

2020 Ruling 2019-0835141R3 - Loss consolidation arrangement

At the time of the Proposed Transactions, Lossco will have the borrowing capacity to obtain a daylight loan, in an amount equal to the amount of Loan 1, directly from an arm's length XXXXXXXXXX and this borrowing will not cause Lossco to contravene its debt covenants. ...
Ruling

2019 Ruling 2018-0787361R3 - Loss consolidation arrangement

At the time of the Proposed Transactions, Lossco will have the borrowing capacity to obtain a daylight loan, in an amount equal to the amount of Loan 1, directly from an arm's length XXXXXXXXXX and this borrowing will not cause Lossco to contravene its debt covenants. ...
Ruling

2021 Ruling 2020-0871841R3 - Loss consolidation arrangement

At the time of the Proposed Transactions, Lossco will have the borrowing capacity to obtain a commercial loan, in an amount equal to the amount of Loan 1, directly from an arm's length financial institution and this borrowing will not cause Lossco to contravene its debt covenants. ...
Ruling

2023 Ruling 2022-0931631R3 - Loss consolidation arrangement

The principal amount of the Daylight Loan will not exceed the amount that Profitco could reasonably be expected to borrow from an arm’s length financial institution and/or debt capital markets and will not cause Profitco to contravene any debt covenants. 33. ...
Ruling

2023 Ruling 2021-0919771R3 - Loss consolidation arrangement

At the time of the Proposed Transactions, Lossco will have the borrowing capacity to obtain a commercial loan, in an amount equal to the amount of Loan 1, directly from an arm's length financial institution and this borrowing will not cause Lossco to contravene its debt covenants. ...

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