7 July 2010 Income Tax Severed Letter 2010-0371091R3 - Supplementary to ruling 2008-029214

By services, 21 December, 2016
Official title
Supplementary to ruling 2008-029214
Language
English
Document number
Citation name
2010-0371091R3
Severed letter type
Miscellaneous
Author
XXXXXXXXXX
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Drupal 7 entity type
Node
Drupal 7 entity ID
394425
Extra import data
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Workflow properties
Workflow state
Published
Workflow changed
Main text

SUMMARY: Supplementary to ruling 2008-029214—none—Advance income tax ruling—Amendments to advance income tax rulingrelating to a time extension and foreign resource property.

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: time extension to ruling # 2008-029214 [] on Foreign resource property

XXXXXXXXXX 2010-037109

XXXXXXXXXX, 2010

Dear. XXXXXXXXXX:

Re: XXXXXXXXXX (the “Corporation”)

Advance Income Tax Ruling dated XXXXXXXXXX, 2009 (the “Ruling”)

    This is in reply to your request for an extension of the deadline for commencement of the proposed transactions referred to in the Ruling (our file number 2008-029214 [] and XXXXXXXXXX as stated in paragraph 17 of the Ruling. Due to XXXXXXXXXX may take more time to complete than anticipated and the proposed transactions cannot proceed until such documentation is in place. Therefore an extension to the time period covered by the Ruling is required. As a result of this development, the following amendments are made to the Ruling:
  • i) Paragraph 17 is replaced by the following like-numbered paragraph
    17. XXXXXXXXXX has confirmed XXXXXXXXXX that:
  • a) the withholding tax on the NSR payments will be 10% of the gross amount thereof; and
  • b) the withholding tax on the cash portion of the exchange proceeds will be 10%.

You have also recently advised that the Net Smelter Return rate stated in paragraph 14 of the Ruling should be reduced from XXXXXXXXXX% to XXXXXXXXXX%.

Notwithstanding the above amendments, the Ruling will continue to be binding on the Canada Revenue Agency subject to the limitations and qualifications set out therein, except that the date for commencement of the proposed transactions is hereby changed from XXXXXXXXXX to XXXXXXXXXX.

Yours truly,

Director

Reorganizations and Resources Division

Income Tax Rulings Directorate

Legislation Policy Regulatory and Affairs Branch