SUMMARY: Amendment to advance tax ruling—none—Advance income tax ruling—Amendment to advance income tax ruling issued in 2011.
Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.
PRINCIPAL ISSUES: Amendment to Advance Tax Ruling 2010-036966 []
POSITION: Granted
REASONS: No impact on rulings given
XXXXXXXXXX
2011-039799
XXXXXXXXXX
XXXXXXXXXX, 2011
Dear XXXXXXXXXX:
Re: XXXXXXXXXX (business number XXXXXXXXXX, XXXXXXXXXX Tax Centre, XXXXXXXXXX Tax Services Office)
- Further to your request of an amendment to our Advance Income Tax Ruling dated XXXXXXXXXX, 2011, our file number 2010-036966 [] (the “Ruling”), issued to the above named taxpayer, the following amendments are made to the Ruling:
- 1. The reference to XXXXXXXXXX; in paragraph 20 is replaced with a reference to XXXXXXXXXX.
- 2. In paragraph 24, “held by the Public” is added after “Each outstanding Common Share” so that the first sentence reads “Each outstanding Common Share held by the Public will be exchanged (without any action on the part of the holder of the Common Shares) for one Class A Share.”
- 3. The reference to “DC” in Ruling B(b) is changed to “the Corporation” so that it reads “the shareholder and the Corporation do not file an election under subsection 85(1) or (2) in respect of the exchange”.
We confirm that the changes described above will not affect the Ruling, which will continue to be binding on the CRA within the constraints set out therein.
Yours truly,
XXXXXXXXXX
For Director
Reorganizations and Resources Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch