2015-0569891R3 Ss. 164(6) carry-back and post-mortem pipeline

Principal Issues: Subsection 164(6) and post-mortem pipeline planning. Whether estate can elect under subsection 164(6) where there is a non-resident beneficiary.

Position: See below

Reasons: See below

Author: XXXXXXXXXX
Section: 164(6), 84(2), 84.1, 245(2), 212(1)(c), 116

XXXXXXXXXX
                                                      2015-056989

Attention: XXXXXXXXXX

XXXXXXXXXX, 2015

Dear XXXXXXXXXX:

Re:   Estate of the late XXXXXXXXXX 
         XXXXXXXXXX
         Advance Income Tax Ruling

This is in reply to your letter of XXXXXXXXXX in which you requested an advance income tax ruling on behalf of the taxpayers referred to above.  The documents submitted with your request are part of this document only to the extent described herein.

We understand that to the best of your knowledge and that of the taxpayers on whose behalf this ruling was requested, none of the issues involved in this ruling are:

(a)   in an earlier return of the taxpayers referred to above or a related person;

(b)   being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers referred to above or a related person;

(c)   under objection by the taxpayers referred to above or a related person;

(d)   in relation to the taxpayers referred to above or a related person, before the courts or the subject of a judgment the time limit for appeal from which has not expired; or

(e)   the subject of a ruling previously considered by the Income Tax Rulings Directorate in relation to the taxpayers referred to above or a related person.

DEFINITIONS

In this letter, the singular should be read as plural and vice versa where the circumstances so require, all monetary amounts are expressed in Canadian dollars, and unless otherwise indicated or the context otherwise requires, the following terms have the meanings specified:

“A Co” means XXXXXXXXXX;

“Act” means the Income Tax Act, R.S.C. 1985 (5th Supp.), c.1, as amended to the date hereof and, unless otherwise stated, all references to a section, subsection, paragraph, subparagraph and clause contained herein are to the Act;

“adjusted cost base” or “ACB” has the meaning assigned by section 54;

“agreed amount” means the amount that the transferor and the transferee of an eligible property have agreed upon in a joint election pursuant to subsection 85(1);

“Amalco” means the company created upon the amalgamation of A Co and Newco as described in Paragraph 21 of this letter;

“arm’s length” has the meaning assigned by subsection 251(1);

“Articles” has the meaning assigned by subsection 2(1) of the BCA;

“BCA” means the Canada Business Corporations Act, RSC 1985, c. C-44, as amended to the date hereof;

“Business Activity” means the management and active trading of a portfolio of XXXXXXXXXX held by A Co, as described in more detail in Paragraph 4;

“Canadian controlled private corporation” or “CCPC” has the meaning assigned by subsection 125(7);

“capital dividend” means a dividend to which subsection 83(2) applies;

“capital dividend account” or “CDA” has the meaning assigned by subsection 89(1);

“capital property” has the meaning assigned by the definition of that term in section 54;

“Child 1” means XXXXXXXXXX, a XXXXXXXXXX of XXXXXXXXXX Mr. A and a resident of Canada for purposes of the Act;

“Child 2” means XXXXXXXXXX, a XXXXXXXXXX of XXXXXXXXXX Mr. A and a non-resident of Canada for purposes of the Act, and a resident of the United States for purposes of the Treaty;

“Child 3” means XXXXXXXXXX, a XXXXXXXXXX of Mr. A and a resident of Canada for purposes of the Act;

“Child 4” means XXXXXXXXXX, a XXXXXXXXXX of Mr. A and a resident of Canada for purposes of the Act;

“Completed Transactions” means the completed transactions which are described in Paragraphs 9 to 16;

“cost amount” has the meaning assigned by subsection 248(1);

“CRA” means the Canada Revenue Agency;

“dividend refund” has the meaning assigned by subsection 129(1);

“eligible dividend” has the meaning assigned by subsection 89(1);

“eligible property” has the meaning assigned by subsection 85(1.1);

“Estate” means the estate of Mr. A;

“fair market value” or “FMV” means the highest price expressed in terms of money or money’s worth, available in an open and unrestricted market between knowledgeable, informed and prudent parties acting at arm’s length, neither party being under any compulsion to transact;

“general rate income pool” or “GRIP” has the meaning assigned by subsection 89(1);

“Loan” means the loan payable by A Co to Mr. A as described in Paragraph 2.1;

“Mr. A” means the late XXXXXXXXXX who, at the time of his death, was a resident of Canada for purposes of the Act;

“Newco” means the corporation to be incorporated as described in Paragraph 18;

“Non-capital losses” has the meaning assigned by subsection 111(8);

“paid-up capital” or “PUC” has the meaning assigned by subsection 89(1);

“Paragraph” means a numbered paragraph in this letter;

“principal amount” has the meaning assigned by subsection 248(1);

“proceeds of disposition” has the meaning assigned by subsection 54;

“Promissory Note” means the note to be issued by Newco to the Estate as described in Paragraph 19;

“Proposed Transactions” means the proposed transactions which are described in Paragraphs 17 to 29;

“Purchased Shares” has the meaning assigned in Paragraph 12;

“refundable dividend tax on hand” or “RDTOH” has the meaning assigned by subsection 129(3);

“Remaining Shares” has the meaning assigned in Paragraph 16;

“SIN” means Canadian social insurance number;

“stated capital” means the amount maintained in the stated capital account attributable to a share for purposes of the BCA;

“taxable Canadian corporation” or “TCC” has the meaning assigned by subsection 89(1);

“taxable dividend” has the meaning assigned by subsection 89(1);

“taxation year” has the meaning assigned by subsection 249(1);

“terminal year” means the last taxation year of Mr. A;

“Treaty” means the Canada-United States Tax Convention (1980), as amended by the Protocols thereto; and,

“V-day basis” means the amount, if any, described in subparagraph 84.1(2)(a.1)(i).

FACTS

1.    A Co was incorporated on XXXXXXXXXX under the BCA.  A Co is a CCPC and a TCC. A Co has a XXXXXXXXXX year-end, and files its tax returns with the CRA’s XXXXXXXXXX Tax Centre.

2.    Immediately prior to the time of his death on XXXXXXXXXX, Mr. A owned all of the issued and outstanding shares of A Co, as follows:

Shareholder           Number & Class of Shares            ACB                 PUC                Approximate FMV

Mr. A                       XXX common                                $XXX               $XXX               $XXX

                               XXX Class A preferred                   $XXX              $XXX               $XXX

                               XXX Class B preferred                   $XXX              $XXX               $XXX

                                                                                                              $XXXXXXXXXX

2.1.  At the time of his death, Mr. A had an outstanding loan receivable from A Co in the amount of $XXXXXXXXXX (the “Loan”).  The Loan resulted from funds loaned by Mr. A to A Co over time.

3.    Under Mr. A’s last will and testament, the executors of the Estate are his four children, Child 1, Child 2, Child 3 and Child 4.  Mr. A left all his shares of A Co, together with all the rest and residue of his Estate, equally to Child 1, Child 2, Child 3 and Child 4.

4.    Prior to his death, Mr. A was actively involved in the Business Activity, and received a salary out of the annual profits of A Co.  A Co is now, and until it is amalgamated with Newco as described in Paragraph 21, will continue to be, XXXXXXXXXX, as it has done for approximately the past XXXXXXXXXX years. The assets of A Co also include a small amount of cash and cash equivalents. The FMV of the assets of A Co that are cash and cash equivalents does not currently exceed, and since XXXXXXXXXX to the date of this letter, has not exceeded, approximately XXXXXXXXXX% of the total FMV of all of A Co’s assets on its year end. A Co will continue to carry on the Business Activity after the implementation of the Proposed Transactions, and the FMV of the assets of A Co that are cash and cash equivalents will comprise less than approximately XXXXXXXXXX% of the FMV of all of A Co’s assets.

5.    Pursuant to paragraph 70(5)(a), all of the shares held by Mr. A in A Co at the time of his death were deemed to be disposed of, and Mr. A was deemed to receive proceeds of disposition equal to the fair market value of such shares immediately prior to his death.  This resulted in the realization by Mr. A of a capital gain of $XXXXXXXXXX in his terminal year.  The shares of A Co were not “qualified small business corporation shares” as that term is defined in subsection 110.6(1), and Mr. A (or his legal representative) could not claim a capital gains exemption under section 110.6 to reduce the capital gain in his terminal year. The shares of A Co held by Mr. A had no V-day basis, and no amount in respect of these shares had been claimed previously as a capital gains exemption under section 110.6 by either Mr. A or an individual with whom Mr. A did not deal at arm’s length.

6.    As of the date of this letter, A Co has approximately the following amounts in its tax accounts:

      (a)   RDTOH       -        XXXXXXXXXX

      (b)   GRIP              -     XXXXXXXXXX

      (c)   CDA               -     XXXXXXXXXX

      (d)   Non-capital losses      - XXXXXXXXXX

7.    Pursuant to paragraph 70(5)(b) of the Act, the Estate was deemed to have acquired Mr. A’s shares of A Co at a cost equal to their FMV immediately prior to Mr. A’s death.  These shares were capital property to Mr. A and are capital property to the Estate.

7.1.  The Estate is resident in Canada for purposes of the Act.

8.    Immediately before XXXXXXXXXX, the tax attributes of the issued and outstanding shares of A Co were as follows:

Shareholder            Number & Class of Shares                  ACB             PUC                    Estimated FMV

Estate                      XXX common                                      $XXX           $XXX                    $XXX

                                XXX Class A preferred                        $XXX           $XXX                    $XXX

                                XXX Class B preferred                        $XXX           $XXX                    $XXX

                                                                                                                $XXXXXXXXXX

COMPLETED TRANSACTIONS

9.    On XXXXXXXXXX, the Articles of A Co were amended to create the following new classes of shares: Class A, Class B, Class C, Class D, Class E, Class F and Class G.

The Class A shares are voting, participating, and entitle the holder to receive unfixed, non-cumulative, discretionary dividends as and when declared by the directors of A Co.

The Class B shares are non-voting, participating, and entitle the holder to receive unfixed, non-cumulative, discretionary dividends as and when declared by the directors of A Co.

The Class C shares are voting, non-participating, redeemable at the option of A Co for an amount equal to the amount for which the shares were issued, and entitle the holder to receive a fixed, monthly, non-cumulative dividend at the discretion of the directors of A Co.

The Class D shares are non-voting, non-participating, redeemable at the option of A Co for an amount equal to the amount for which the shares were issued, and entitle the holder to receive a fixed, monthly, non-cumulative dividend at the discretion of the directors of A Co.

The Class E shares are voting, non-participating, redeemable at the option of A Co or the holder thereof for an amount equal to the amount for which the shares were issued, and entitle the holder to receive a fixed, monthly, non-cumulative dividend at the discretion of the directors of A Co.

The Class F shares are non-voting, non-participating, redeemable at the option of A Co or the holder thereof for an amount equal to the amount for which the shares were issued, and entitle the holder to receive a fixed, monthly, non-cumulative dividend at the discretion of the directors of A Co.

The Class G shares are non-voting, non-participating, redeemable at the option of A Co or the holder thereof for an amount equal to XXXXXXXXXX and entitle the holder to receive a fixed, monthly, non-cumulative dividend at the discretion of the directors of A Co.

9.1.  Upon the issuance of the amended Articles, the XXXXXXXXXX common shares, XXXXXXXXXX Class A preferred shares, and XXXXXXXXXX Class B preferred shares of A Co that were issued and outstanding at that time were exchanged in the course of a reorganization of the capital of A Co for XXXXXXXXXX Class A, XXXXXXXXXX Class E and XXXXXXXXXX Class F shares, respectively, as described below.

(a)   The XXXXXXXXXX common shares of A Co outstanding at that time were exchanged for XXXXXXXXXX Class A shares of A Co, and an amount equal to the stated capital of the XXXXXXXXXX common shares was deducted therefrom and an amount equal thereto was added to the stated capital account of the XXXXXXXXXX Class A shares. The XXXXXXXXXX Class A shares of A Co had a PUC, ACB and FMV equal to the aggregate ACB, PUC and FMV of the previously issued and outstanding XXXXXXXXXX common shares of A Co.

(b)   The XXXXXXXXXX Class A preferred shares of A Co outstanding at that time were exchanged for XXXXXXXXXX Class E shares of A Co and an amount equal to the stated capital of the XXXXXXXXXX Class A preferred shares was deducted therefrom and an amount equal thereto was added to the stated capital account of the XXXXXXXXXX Class E shares. The XXXXXXXXXX Class E shares of A Co had a PUC, ACB and FMV equal to the aggregate ACB, PUC and FMV of the previously issued and outstanding XXXXXXXXXX Class A preferred shares of A Co.

(c)   The XXXXXXXXXX Class B preferred shares of A Co issued outstanding at that time were exchanged for XXXXXXXXXX Class F shares of A Co, and an amount equal to the stated capital of the XXXXXXXXXX Class B preferred shares was deducted therefrom and an amount equal thereto was added to the stated capital account of the XXXXXXXXXX Class F shares. The XXXXXXXXXX Class F shares of A Co had a PUC, ACB and FMV equal to the aggregate ACB, PUC and FMV of the previously issued and outstanding XXXXXXXXXX Class B preferred shares of A Co.

Immediately after the exchanges described above, the previously issued and outstanding XXXXXXXXXX common shares, XXXXXXXXXX Class A preferred shares, and XXXXXXXXXX Class B preferred shares of A Co were cancelled.

10.   Immediately after the share exchanges described in Paragraph 9.1, the Estate’s shareholdings in A Co were as follows:

Shareholder                      Number & Class of Shares              ACB              PUC               Estimated FMV

Estate                                XXX Class A                                   $XXX             $XXX              $XXX

                                          XXX Class E                                   $XXX              $XXX              $XXX

                                          XXX Class F                                   $XXX               $XXX              $XXX

11.   Immediately after the share exchanges described in Paragraph 9.1, the Estate transferred all of its shares in A Co, being XXXXXXXXXX Class A shares, XXXXXXXXXX Class E shares, and XXXXXXXXXX Class F shares, to A Co in exchange for XXXXXXXXXX Class B shares in A Co. An amount equal to balance in the stated capital account of each of the XXXXXXXXXX Class A, XXXXXXXXXX Class E and XXXXXXXXXX Class F shares in A Co was deducted therefrom, and an amount equal to the aggregate of these amounts was added to the stated capital account of the XXXXXXXXXX Class B shares in A Co. Immediately thereafter, the Estate subscribed for XXXXXXXXXX Class C shares of A Co for $XXXXXXXXXX in the aggregate.

12.   After the transfer described in Paragraph 11, the Estate sold, and A Co repurchased, XXXXXXXXXX Class B shares (the “Purchased Shares”) in the capital stock of A Co, being XXXXXXXXXX% of all of the issued and outstanding shares of A Co immediately before that time, for an aggregate purchase price equal to their FMV. A Co was deemed to have paid a dividend to the Estate equal to the amount by which the FMV of the Purchased Shares exceeded the PUC of such shares.  The proceeds receivable by the Estate will be allocated to Child 2, and paid by the Estate, less withholding tax, to Child 2 by the issuance of a non-interest bearing demand promissory note.

13.   To the extent that A Co has RDTOH on its year end and is deemed to receive a dividend by virtue of the redemption of shares described in Paragraph 12, it will apply for a dividend refund pursuant to paragraph 129(1)(a) equal to the lesser of (i) 1/3 of the taxable dividend paid by A Co and (ii) the outstanding balance of A Co’s RDTOH at the end of the relevant taxation year.

14.   On the disposition of the Purchased Shares described in Paragraph 12, the Estate will claim a capital loss equal to the difference between the proceeds of disposition (determined pursuant to paragraph (j) of the definition thereof) and the ACB of the Purchased Shares.

15.   On or before the last day of the Estate’s first taxation year, the executors of the Estate made the election described in subsection 164(6) in order that the Estate’s capital loss arising on the purchase by A Co of the Purchased Shares was deemed to be a capital loss of Mr. A in his terminal year.  The Estate had no other capital gains in its first taxation year.

16.   After the purchase of the Purchased Shares by A Co, the Estate owned XXXXXXXXXX Class B shares and XXXXXXXXXX Class C shares in A Co (the “Remaining Shares”).

PROPOSED TRANSACTIONS

17.   The Loan will be repaid by A Co to the extent of its available cash.

18.   The Estate will incorporate a new company under the CBCA (“Newco”).  The Estate will subscribe for 1 Class A share of Newco for $XXXXXXXXXX.  Newco will, at all relevant times and for purposes of the Act, be a TCC and a CCPC.

19.   The Estate will transfer the Remaining Shares to Newco.  As consideration therefor, the Estate will receive XXXXXXXXXX additional Class A shares of Newco and a non-interest bearing demand promissory note (the “Promissory Note”) having a principal amount equal to the ACB of the Remaining Shares, less $XXXXXXXXXX.

The Estate and Newco will jointly elect, in prescribed form and within the time referred to in subsection 85(6) of the Act, to have the provisions of subsection 85(1) apply to the transfer of the Remaining Shares to Newco.  The agreed amount in respect of the transfer will equal the ACB of the Remaining Shares immediately before the transfer, subject to the application of paragraph 85(1)(c) in the event there has been any decrease in the FMV of the Remaining Shares. For greater certainty, the agreed amount will not be less than the least of the amounts specified in subparagraphs 85(1)(c.1)(i) and (ii), and will not be less than the amount described in paragraph 85(1)(b).

Newco will add to the stated capital of the XXXXXXXXXX Class A shares issued by Newco to the Estate an amount equal to $XXXXXXXXXX in the aggregate, which, for greater certainty, will not exceed the maximum amount that could be added to the PUC of these shares, having regard to paragraph 84.1(1)(a). 

As a result of the transactions described above, the Estate will hold XXXXXXXXXX Class A shares in Newco and the Promissory Note receivable.

20.   A Co will remain a separate and distinct entity for a period of at least one year after the transfer of the Remaining Shares described in Paragraph 19, during which time A Co will continue to carry on the Business Activity in the same manner as it did before the implementation of the Proposed Transactions and the death of Mr. A.  For greater certainty, after the Proposed Transactions the asset allocation as between cash and cash equivalents, and A Co’s other investment assets, will be maintained, and the Business Activity will continue to be carried on in the same manner as it has been carried on for the past XXXXXXXXXX years. 

21.   After at least one year has elapsed from the date of the transfer of the Remaining Shares described in Paragraph 19, A Co and Newco will be amalgamated pursuant to subsection 177 of the BCA to form Amalco.

22.   In accordance with subsection 87(1) of the Act, all the property and all the liabilities of A Co and Newco immediately prior to the amalgamation will become property and liabilities of Amalco, and the Estate will own all of the issued and outstanding shares in Amalco. 

23.   Reserved 

24.   The amount owing in respect of the Promissory Note may be gradually paid by Amalco to the Estate over a period of at least one year after the amalgamation of Newco and A Co, but the amount paid in any quarter of that year will not exceed XXXXXXXXXX% of the principal amount of the Promissory Note when it was issued.

While Amalco may sell some of its marketable securities in order to make the abovementioned payments in respect of the Promissory Note, it will continue carrying on the Business Activity with the remaining marketable securities and other investments held by it.

25.   After the Promissory Note has been paid in full and cancelled, Amalco will resolve to wind up and it will distribute its assets to the Estate.  Pursuant to the winding up agreement the debts, obligations and liabilities of Amalco will be extinguished or provided for, and, after the interests of all of the creditors are satisfied, all of the remaining property of Amalco will be distributed to the Estate. 

26.   Reserved 

27.   Reserved

28.   Within a reasonable time following the receipt of any dividend refund on the dissolution of Amalco, Articles effecting dissolution will be filed by Amalco, and upon receipt of a Certificate of Dissolution, Amalco will be dissolved.

29.   By virtue of a written agreement between all of the legatees, who are also the executors, of the Estate, no portion of the amount received by the Estate upon the dissolution of Amalco will be allocated to Child 2 and accordingly, to the extent that there is an amount in the capital dividend account of Amalco, this amount will only be distributed to Canadian resident legatees of the Estate.

ADDITIONAL INFORMATION

30.   We understand that United States tax counsel has indicated to you that unless Amalco is dissolved in a reasonable time following the purchase of the Purchased Shares by Newco, Child 2 will suffer adverse tax consequences with respect to a dividend received by him in the United States.  Thus, the aforementioned transactions are being undertaken for United States tax purposes as a “Plan of Liquidation” of A Co, which will encompass all of the Completed Transactions and the Proposed Transactions.  It is your understanding that as long as all distributions made directly or indirectly from A Co are made pursuant to the “Plan of Liquidation”, such distributions should be taxed as capital proceeds to Child 2, who will receive such distributions as capital gains for United Stated income tax purposes, rather than as dividends which would be taxed at a higher rate in the United States.

30.1. After the transaction described in Paragraph 12, and by virtue of the agreement described in Paragraph 29, Child 2 will no longer have any interest in the shares of A Co.

30.2. Child 2 has not been resident in Canada for at least XXXXXXXXXX years.

PURPOSES OF THE COMPLETED TRANSACTIONS

31.   The purpose of amending the Articles of A Co, converting the issued and outstanding shares of A Co into three new classes of shares as described at Paragraph 9.1, and transferring these newly issue shares to A Co in exchange for a single class of shares of A Co, as described at Paragraph 11, was to simplify the capital structure of A Co prior to the share redemption and post-mortem pipeline transaction by converting the three different previously issued and outstanding classes of shares into a single class of shares. This purpose was accomplished in the particular manner described in Paragraphs 9.1 and 11 for practical rather than tax considerations.

32.   Since, pursuant to the United States Internal Revenue Code, A Co is a passive foreign investment corporation (“PFIC”) in relation to Child 2, the purpose of the Completed Transactions is to remove Child 2 as a shareholder of A Co in a manner that will ensure that he can receive any distribution from A Co as a capital gain for United States income tax purposes and avoid the complications and negative tax consequences resulting from being a United States resident shareholder of a PFIC.

PURPOSE OF THE PROPOSED TRANSACTIONS

33.   The purpose of the Proposed Transactions is to return to the legatees of Mr. A, other than Child 2, an amount equal to the FMV of the issued and outstanding shares of A Co (after the payment to Child 2 of his percentage entitlement to this amount by way of dividend) while minimizing the inherent double tax exposure resulting from the deemed disposition of such shares upon Mr. A’s death.

RULINGS

Provided that the preceding statements constitute a complete and accurate disclosure of all relevant facts, completed and proposed transactions, and the purposes of the Completed Transactions and the Proposed Transactions, and additional information, and provided that the Completed Transactions were, and the Proposed Transactions are, completed as described above, our rulings are as follows:

A.    Section 84.1 of the Act will not apply to deem the Estate to have received a dividend upon the transfer of the Remaining Shares to Newco, as described in Paragraph 19.

B.    Subsection 84(2) of the Act will not apply as a result of the Proposed Transactions, in and by themselves, to deem A Co to have paid, and the Estate to have received, a dividend on the Remaining Shares held by the Estate.

C.    Subsection 245(2) will not apply as a result of the Proposed Transactions, in and by themselves, to redetermine the tax consequences stated in the rulings given above.

Our rulings are given subject to the limitations set out in Information Circular 70-6R5 dated May 17, 2002, and are binding on the CRA provided the Proposed Transactions are completed within six months of the date of this letter.  Our rulings are based on the law as it currently reads and do not take into account any proposed amendments to the Act or Regulations.

Our Comments

Nothing in this ruling should be construed as implying that CRA has reviewed any tax consequences relating to the facts or the Proposed Transactions other than those described in the rulings given above, or has agreed:

(a)   to the fair market value or adjusted cost base of any asset or to the paid-up capital of any share;

(b)   that, under the terms of Mr. A’s last will and testament, the executors of his Estate are able to administer the Estate in a manner that is consistent with the terms of the written agreement described in Paragraph 29; or

(c)   to any other tax consequences relating to any transaction described herein other than those specifically described in the rulings given above.

Furthermore, none of the rulings given in this letter are intended to apply to, or in the event of, the operation of a price adjustment clause, since such adjustment will be due to circumstances that do not constitute proposed transactions that are seriously contemplated.  The general position of the CRA with respect to price adjustment clauses is stated in Income Tax Folio S4-F3-C1, dated March 28, 2013.

An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover.

Yours truly,

XXXXXXXXXX
Manager
Reorganizations and Resources Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch

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