Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ADRC.
Principal Issues:
Request for amendments to the facts and the proposed transactions as well as a minor revision to an advance income tax ruling in respect of advance ruling # 2001-009054 (the "Ruling").
Position TAKEN:
Requested amendments were incorporated into the Ruling by way of this supplemental ruling.
Reasons FOR POSITION TAKEN:
N/A
XXXXXXXXXX 2002-011649
XXXXXXXXXX, 2002
Dear XXXXXXXXXX:
Re: Advance Income Tax Ruling
XXXXXXXXXX
XXXXXXXXXX
XXXXXXXXXX
Ruling # 2001-009054 (the "Ruling")
This is in reply to your e-mail dated XXXXXXXXXX in which you requested amendments to the Ruling issued to the above-referenced taxpayers on XXXXXXXXXX, 2001. The terms used herein have the meaning assigned in the Ruling.
Following our review of your request, the Ruling is revised as follows:
1. In the definition section, paragraph (rr), XXXXXXXXXX are replaced by the words XXXXXXXXXX.
2. XXXXXXXXXX.
3. Paragraph 16, subparagraph 2, delete the 1st sentence and insert the following in its place:
On incorporation, Canco # 2 XXXXXXXXXX, will subscribe for and Newco will issue to Canco # 2 or the said corporation controlled directly or indirectly XXXXXXXXXX common shares for aggregate consideration of $XXXXXXXXXX.
4. Paragraph 27, immediately after the last sentence, insert a new subparagraph which reads as follows:
XXXXXXXXXX.
5. XXXXXXXXXX.
6. In Ruling B line 2, the reference to paragraph "29" is replaced by a reference to paragraph "30".
Notwithstanding the above-mentioned changes, we confirm that the Ruling will continue to be binding on the Canada Customs and Revenue Agency in the manner described therein, provided that the proposed transactions are completed on or before XXXXXXXXXX.
Yours truly,
XXXXXXXXXX
for Director
Financial Industries Division
Income Tax Rulings Directorate
Policy and Legislation Branch