Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère.
XXXXXXXXXX XXXXXXXXXX 1-991922 XXXXXXXXXX
Attention: XXXXXXXXXX
XXXXXXXXXX, 1999
Dear Sirs:
Re: XXXXXXXXXX
XXXXXXXXXX
XXXXXXXXXX
XXXXXXXXXX
Advance Income Tax Ruling
This is in reply to your letter of XXXXXXXXXX, in which you advised of changes to the Definitions and Proposed Transactions described in our letter of XXXXXXXXXX, 1999 on our file number 3-991044 (the "Ruling"). (Terms defined in the Ruling to have a certain meaning have the same meaning when used in this letter.)
As a result of your letter the following changes are made to the Ruling:
1. In the Definitions, delete the definition "(bb)" and replace with the following:
"(bb) "Subco" means the corporation previously incorporated by an employee of XXXXXXXXXX (the "Employee") under the CBCA. Subco is a taxable Canadian corporation and its one common share issued on incorporation for nominal consideration is held by the Employee. Subco is organized as a shelf corporation and has carried on no activities since its incorporation and has no assets or liabilities. Subco will be acquired by XXXXXXXXXX as described in paragraph 11 below."
2. In paragraph 11, delete the first subparagraph and replace with the following:
"XXXXXXXXXX will acquire the one common share of Subco held by the Employee for consideration equal to the fair market value of the one common share at that time."
3. In paragraph 15(b), third subparagraph, first line, delete the word "stated".
We confirm that the above changes will not affect the rulings given in the Ruling and that those rulings will continue to be binding as indicated therein.
Yours truly,
for Director
Reorganization and International Division
Income Tax Rulings and
Interpretations Directorate
Policy and Legislation Branch
2
.../cont'd