2017 Ruling 2017-0706211R3 - Standard Loss Consolidation -- summary under Subparagraph 20(1)(c)(i)

CRA provided standard loss-shifting rulings under transactions in which three losscos in the group annually shift losses to a single newly-incorporated Lossco, which is then sold at FMV to a Profitco in the group whose ownership is redacted, with the Lossco immediately wound-up into the Profitco under s. 88(1.1). The interest-bearing loans, whose proceeds were used by the new Lossco to subscribe for preferred shares of Newcos, were made to Lossco on a limited recourse basis, i.e., recourse was limited to such preferred shares.