2011 Ruling 2011-0394031R3 - Related Foreign Entity Financing - Supplemental

By services, 17 December, 2016
Bundle date
Official title
Related Foreign Entity Financing - Supplemental
Language
English
Document number
Citation name
2011-0394031R3
Severed letter type
Ruling
Author
XXXXXXXXXX
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
392881
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "2011-01-01 07:00:00",
"field_tags": []
}
Workflow properties
Workflow state
Published
Workflow changed
Main text

Principal Issues: Clarification of facts in ruling 2010-037639

XXXXXXXXXX
									2011-039403
									XXXXXXXXXX 

XXXXXXXXXX , 2011

Dear XXXXXXXXXX :

Re: XXXXXXXXXX ("Canco")

Further to our recent discussions (XXXXXXXXXX ), we confirm that paragraph 8 of income tax ruling 2010-037639 is replaced with the following:

8. Dutchco will use the cash received from the Dutchco Loan to makes loans to or investments in other foreign entities within the Pubco Group (other than a foreign affiliate of Canco or a partnership in which a foreign affiliate of Canco has an interest) depending on the cash requirements of the relevant entities.

We confirm that the rulings provided in our document 2010-037639 continue to be binding on the CRA, subject to the limitations and qualifications set forth in that document.

Yours truly,

for Director
International and Trusts Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch