2009 Ruling 2008-0289771R3 - Loss Consolidation -- summary under Paragraph 111(1)(a)

Favourable ruling was given with respect to transactions in which the following three transactions are repeated until the right amount of interest-bearing data is created: Lossco Sub transfers its portfolio to its parent, Lossco in exchange for an interest-free demand note, Lossco transfers the portfolio to a newly-created subsidiary ("Newco") in exchange for an interest-bearing demand note, and Newco transfers the portfolio to Lossco Sub in exchange for Lossco Sub preferred shares.