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.
Principal Issues: Minor amendments to ruling 2000 - 000417
Position: OK
Reasons: Typos only
XXXXXXXXXX XXXXXXXXXX 2000-001071 XXXXXXXXXX
Attention: XXXXXXXXXX
XXXXXXXXXX, 2000
Dear Sirs:
Re: Advance Income Tax Ruling - XXXXXXXXXX
We are writing in response to your correspondence of XXXXXXXXXX regarding the advance income tax ruling (our file 2000-000417) dated XXXXXXXXXX, 2000 issued to your firm with respect to the above-referenced corporation.
With respect to that ruling, we advise that the following amendments are made as indicated:
Paragraph 7 of the above noted advance income tax ruling is amended to read as follows:
The stated capital and the "paid-up capital", as that term is defined in subsection 89(1) of the Act, of the common shares of each Subsidiary Corporation is as follows:
CCO $ XXXXXXXXXX DCO $ XXXXXXXXXX ECO $ XXXXXXXXXX FCO $ XXXXXXXXXX GCO $ XXXXXXXXXX
Paragraph 16 of the above noted advance income tax ruling is amended to read as follows:
On the same day as the proposed transaction set out in paragraph 15, above but subsequent thereto, ACO shall lend the aggregate amount of $XXXXXXXXXX to the Subsidiary Corporations on a demand basis bearing interest at Prime Rate less 3/4 of one percent. For this purpose, "Prime Rate" means the floating annual rate of interest established from time to time by the XXXXXXXXXX as the base rate it will use to determine rates of interest payable on Canadian dollar loans to customers in Canada. Interest will be due and payable monthly in arrears. The amount of the loan to each Subsidiary Corporation shall be as follows:
CCO $ XXXXXXXXXX DCO $ XXXXXXXXXX ECO $ XXXXXXXXXX FCO $ XXXXXXXXXX GCO $ XXXXXXXXXX
This is to confirm that the amendments noted above will not affect the advance income tax rulings previously provided.
We trust that this is the information which you require.
Yours truly,
for Director
Financial Industries Division
Income Tax Rulings Directorate
Policy and Legislation Branch