17 December 2008 External T.I. 2007-0253031E5 - Loss Consolidation Arrangement -- summary under Paragraph 111(1)(a)

Ruling request denied because the Lossco did not have the borrowing capacity to effect the loss consolidation arrangement: "It is the borrowing capacity of the entity that actually suffers the losses, rather than the borrowing capacity of the affiliated group as a whole, that is relevant in the particular circumstances."