2016-0630761R3 Transfer of Shares

Principal Issues: (1) Will a rollover of shares of a foreign affiliate from a Canadian corporation to another foreign affiliate followed by a transfer to a related Canadian resident corporation (that is not a “Canadian corporation”) for less than FMV trigger the benefit provisions in subsections 15(1), 56(2), 69(4) or 246(1)? (2) Will subsection 245(2) apply to the transfer?

Position: (1) In the particular circumstances, no. (2) No.

Reasons: (1) Ruling granted previously in similar circumstances - transaction not to confer benefit – in particular, transaction at less than FMV permitted tax deferred transaction with restriction of ACB of FA1 shares to amount transferred for. (2) The transactions are not a misuse or abuse of the Act or its provisions. There is no avoidance of income tax achieved, only a deferral – not clear that policy of Act intended to deny deferral in these circumstances.

Author: XXXXXXXXXX
Section: 15(1), 40(3), 53(2)(b), 54, 56(2), 85.1(3), 85.1(4), 69(1), 69(4), 93(1), 93(1.1), 92(2), 93(1.11), 113(1), 258(3), 258(5), 5901(2), 5902(6)

XXXXXXXXXX                                                                                                                              2016-063076

XXXXXXXXXX, 2016

Dear XXXXXXXXXX:

Re:   Advance Income Tax Ruling
        XXXXXXXXXX

This is in reply to your letter of XXXXXXXXXX, requesting an advance income tax ruling on behalf of the above-named taxpayers.  In your subsequent letters and emails, the latest of which was dated XXXXXXXXXX, you provided additional information concerning the facts, subject transactions and proposed transactions described in your original letter. We also acknowledge the information provided during our various telephone conversations (XXXXXXXXXX).

We understand that, to the best of your knowledge and that of the above-named taxpayers, none of the issues involved in the ruling request is:

(i)   in an earlier tax return of the above-named taxpayers or a related person;

(ii)  being considered by a tax services office or a tax centre in connection with a tax return already filed by the above-named taxpayers or a related person;

(iii) under objection by the above-named taxpayers or a related person;

(iv)  before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or

(v)   the subject of a ruling previously issued by the Directorate to the above-named taxpayers or a related person.

This document is based solely on the Facts, Subject Transactions and Proposed Transaction, and Additional Information described below.  Any documentation submitted in respect of your request does not form part of the Facts, Subject Transactions and Proposed Transaction or Additional Information and any references thereto are provided solely for the convenience of the reader.

Unless otherwise stated:

(i)   all references to a statute are to the Income Tax Act R.S.C. 1985 (5th Supp.), c.1, as amended (the “Act”), and all terms and conditions used herein that are defined in the Act have the meaning given in such definitions, and

(ii)  all references to monetary amounts are in Canadian dollars.

The following terms referred to throughout this document will have the following meaning:

(a)   “ACB” means “adjusted cost base” as that term is defined in section 54;

(b)   “ACo” means XXXXXXXXXX;

(c)   “ACo Group” means, collectively, ACo and its direct and indirectly-owned subsidiaries;

(d)   XXXXXXXXXX;

(e)   XXXXXXXXXX;

(f)   “BCA” means the Business Corporations Act XXXXXXXXXX;

(g)   “BCo” means XXXXXXXXXX;

(h)   “BCo Common Shares” has the meaning assigned by Paragraph 4;

(i)   “BCo Note” has the meaning assigned by Paragraph 17;

(j)   “BCo Note Cash Payment” has the meaning assigned by Paragraph 19;

(k)   “BCo Purchase Price” has the meaning assigned by Paragraph 17;

(l)   “BCo Transfer Agreement” has the meaning assigned by Paragraph 17;

(m)   “capital property” has the meaning assigned by section 54;

(n)   “consolidated net surplus” of a foreign affiliate of a corporation means, at a particular time, the amount that would be determined under subparagraph 5902(1)(a)(i) of the Regulations to be the net surplus of the affiliate in respect of the corporation at that time if that subparagraph were applicable at that time;

(o)   XXXXXXXXXX;

(p)   “controlled foreign affiliate” has the meaning assigned by subsection 95(1);

(q)   “Country A” means XXXXXXXXXX;

(r)   “Country B” means XXXXXXXXXX;

(s)   “excluded property” has the meaning assigned by subsection 95(1);

(t)   “exempt surplus” has the meaning assigned by subsection 5907(1) of the Regulations;

(u)   “FA1” means XXXXXXXXXX;

(v)   “FA1 Shares” has the meaning assigned by Paragraph 10;

(w)   “FA2” means XXXXXXXXXX;

(x)   “FA3” means XXXXXXXXXX;

(y)   “fair market value” or “FMV” means the highest price available in an open and unrestricted market, between informed, prudent parties, acting at arm’s length and under no compulsion to act and contracting for a taxable purchase and sale expressed in terms of cash;

(z)   “FAPI” means “foreign accrual property income” as defined in subsection 95(1);

(aa)  XXXXXXXXXX;

(bb)  “Foreign Act 1” means the XXXXXXXXXX;

(cc)  “Foreign Act 2” means the XXXXXXXXXX;

(dd)  “Foreign Act 3” means the XXXXXXXXXX;

(ee)  “foreign affiliate” has the meaning assigned by subsection 95(1);

(ff)  XXXXXXXXXX;

(gg)  “net surplus” has the meaning assigned by subsection 5907(1) of the Regulations;

(hh)  “New FA” means the XXXXXXXXXX described in Paragraph 15;

(ii)  “New FA Common Shares” has the meaning assigned by Paragraph 15;

(jj)  “New FA Distribution” has the meaning assigned by Paragraph 20;

(kk)  “New FA XXXXXXXXXX Agreement” has the meaning assigned by Paragraph 15;

(ll)  “New FA Purchase Price” has the meaning assigned by Paragraph 16;

(mm)  “New FA Transfer Agreement” has the meaning assigned by Paragraph 16;

(nn)  “Paragraph” means a numbered paragraph in this letter;

(oo)  “Proposed Transaction” means the transaction set out in Paragraph 21;

(pp)  “public corporation” has the meaning assigned by subsection 89(1);

(qq)  “RCB” means “relevant cost base” as that term is defined in subsection 95(4) if that definition were read without regard to paragraph (b) thereof;

(rr)  “Regulations” means the Income Tax Regulations, C.R.C., c. 945, as amended;

(ss)  XXXXXXXXXX;

(tt)  “Subject Transactions” means the transactions set out in Paragraphs 15 to 20;

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

(vv)  “Transfer Amount” means an amount equal to the sum of (i) the aggregate RCB to New FA of its FA1 Shares at the time of their transfer by New FA to BCo, as described in Paragraph 17, and (ii) the consolidated net surplus of FA1 at such time, such sum not to exceed the aggregate FMV of such FA1 Shares at such time.

FACTS

Aco

1.    ACo is a XXXXXXXXXX. It is a taxable Canadian corporation, XXXXXXXXXX. ACo carries on a XXXXXXXXXX business and is the parent corporation for directly and indirectly-owned subsidiaries that collectively comprise the ACo Group.

2.    ACo’s executive offices are situated at XXXXXXXXXX. ACo’s Taxation Centre is the XXXXXXXXXX Taxation Centre and its Tax Services Office is the XXXXXXXXXX Tax Services Office. ACo’s business number is XXXXXXXXXX.

BCo

3.    XXXXXXXXXX

4.    On XXXXXXXXXX, BCo XXXXXXXXXX under the Foreign Act 2 XXXXXXXXXX.

5.    The issued and outstanding share capital of BCo consists of XXXXXXXXXX BCo Common Shares, all of which are owned by ACo.

6.    XXXXXXXXXX, the central management and control of BCo has been exercised in Canada and, accordingly, XXXXXXXXXX, BCo XXXXXXXXXX resident in Canada for purposes of the Act.

7.    BCo holds shares of corporations that, directly or indirectly through subsidiaries, carry on XXXXXXXXXX businesses in Country A XXXXXXXXXX. The assets of BCo consist principally of the shares of FA2 and FA3.

8.    XXXXXXXXXX

9.    BCo’s Taxation Centre is the XXXXXXXXXX Taxation Centre and its Tax Services Office is the XXXXXXXXXX Tax Services Office. BCo’s business number is XXXXXXXXXX.

FA1

10.   FA1 is a corporation incorporated under the Foreign Act 1 and a non-resident of Canada for purposes of the Act. The issued and outstanding share capital of FA1 consists of common shares (“FA1 Shares”), all of which were owned by ACo. FA1 holds shares of corporations that, directly or indirectly through subsidiaries, carry on XXXXXXXXXX businesses in Country A. FA1 is a controlled foreign affiliate of ACo. ACo held the FA1 Shares as capital property.

11.   FA1 maintains its surplus accounts in the currency of Country A in accordance with subsection 5907(6) of the Regulations.  The consolidated net surplus of FA1 consists only of exempt surplus.

12.   As at XXXXXXXXXX, the aggregate ACB to ACo of its FA1 Shares was approximately $XXXXXXXXXX. ACo expects that, at the time of undertaking the Subject Transactions, the FMV of the FA1 Shares exceeded the total of (a) the ACB to ACo of its FA1 Shares, and (b) the consolidated net surplus of FA1.

FA2 and FA3

13.   FA2 is a corporation incorporated under the Foreign Act 1, a non-resident of Canada for purposes of the Act and a direct wholly-owned subsidiary of BCo.  FA2 is a XXXXXXXXXX company under the Foreign Act 3 and holds shares of corporations that, directly or indirectly through subsidiaries, carry on XXXXXXXXXX businesses in Country A.

14.   FA3 is a XXXXXXXXXX incorporated under the laws of Country B, a non-resident of Canada for purposes of the Act and a direct wholly-owned subsidiary of BCo. FA3 is XXXXXXXXXX company.

SUBJECT TRANSACTIONS

15.   On XXXXXXXXXX, ACo incorporated XXXXXXXXXX (“New FA”) under the Foreign Act 2. On the incorporation of New FA, ACo subscribed for one New FA Common Share for XXXXXXXXXX$XXXXXXXXXX.  For purposes of the Act, New FA is a corporation not resident in Canada and a foreign affiliate and controlled foreign affiliate of ACo.

The XXXXXXXXXX of New FA (the “New FA XXXXXXXXXX Agreement”) provides, among other things, that:

(a)   “Share” shall mean XXXXXXXXXX in New FA. Subject to the Foreign Act 2 and the New FA XXXXXXXXXX Agreement, Shares may be issued in separate classes, each such class having its own distinctive rights and privileges;

(b)   the only class of Shares provided for in the New FA XXXXXXXXXX Agreement is designated as “Common Shares” (“New FA ommon Shares”);

(c)   “Stated Capital” in respect of the Shares of a class shall be the amount recorded in the Stated Capital account of such class of Shares from time to time as provided in the terms of the New FA XXXXXXXXXX Agreement, and the Stated Capital in respect of a Share of a class shall mean the pro rata portion (based upon the number of Shares of the class that are then outstanding) of the Stated Capital in respect of the Shares of the class;

(d)   “Capital Amount” in respect of a Share shall be the amount of the capital contribution made by a holder in respect of such Share to be maintained in the same currency as the Stated Capital in respect of the Shares of the class;

(e)   New FA shall maintain a separate Stated Capital account for each class of Shares it issues. On the issuance of Shares of a particular class, there shall be added to the Stated Capital account of that class their Capital Amounts. There shall be deducted from the Stated Capital account of a class of Shares such amount of the Stated Capital of that class as was reduced and paid to the holders of Shares pursuant to the New FA XXXXXXXXXX Agreement; and

(f)   notwithstanding subparagraph (e) above, on the issuance of Shares of a particular class, New FA may add to the Stated Capital of that class the whole or any part of their Capital Amounts where such Capital Amounts arise from the contribution of shares of, or another interest or right in, a corporation or other entity that immediately before the exchange, or that because of the exchange, did not deal with New FA at arm’s length within the meaning of that expression in the Act.

XXXXXXXXXX

16.   On XXXXXXXXXX, ACo transferred to New FA all of its FA1 Shares pursuant to a share transfer agreement (the “New FA Transfer Agreement”) at a purchase price equal to the aggregate FMV of such FA1 Shares at the time of the transfer (the “New FA Purchase Price”). As sole consideration for the transfer, New FA issued to ACo New FA Common Shares having an aggregate FMV equal to the aggregate FMV of the FA1 Shares, at the time of the transfer, so transferred by ACo to New FA.

The New FA Transfer Agreement specifies that the New FA Purchase Price is subject to a price adjustment clause, which will adjust the New FA Purchase Price and the number of New FA Common Shares issued by New FA upward or downward depending on any adjustment to the FMV of the FA1 Shares transferred by ACo to New FA, as described in this Paragraph.

Pursuant to the resolution of the board of directors of New FA authorizing the issuance of New FA Common Shares pursuant to the New FA Transfer Agreement, the Stated Capital in respect of the New FA Common Shares was increased as a result of such issuance by an amount equal to the principal amount of the BCo Note, as such principal amount may be adjusted as described in Paragraph 17.

17.   On XXXXXXXXXX, New FA transferred to BCo all of its FA1 Shares pursuant to a share transfer agreement (the “BCo Transfer Agreement”) at a purchase price (the “BCo Purchase Price”) equal to the Transfer Amount. As sole consideration for the transfer, BCo issued to New FA a non-interest bearing demand promissory note (the “BCo Note”) having a principal amount and FMV equal to the BCo Purchase Price.

The BCo Transfer Agreement specifies that the BCo Purchase Price and the principal amount of the BCo Note issued to New FA in exchange for the FA1 Shares are subject to a price adjustment clause, which will adjust the BCo Purchase Price and the principal amount of the BCo Note issued to New FA upward or downward depending on any adjustment to the Transfer Amount.

The terms of the BCo Note contain an acknowledgement that the principal amount of the BCo Note is subject to an adjustment clause, which will adjust the principal amount of the BCo Note upward or downward depending on any adjustment provided for under the BCo Purchase Agreement, as described in this Paragraph.

18.   On XXXXXXXXXX, ACo subscribed for additional BCo Common Shares for cash in an amount equal to the principal amount of the BCo Note.

The total share subscription amount as described herein is subject to an adjustment clause, which will adjust the total subscription amount and the number of BCo Common Shares issued by BCo upward or downward depending on any adjustment to the principal amount of the BCo Note, as described in Paragraph 17.

19.   On XXXXXXXXXX, BCo paid to New FA an amount in cash equal to the principal amount and FMV of the BCo Note (the “BCo Note Cash Payment”) in full repayment and satisfaction of the BCo Note.

The amount of the BCo Note Cash Payment is subject to an adjustment clause, which will adjust the amount of the BCo Note Cash Payment upward or downward depending on any adjustment to the principal amount of the BCo Note, as described in Paragraph 17.

20.   On XXXXXXXXXX, the Stated Capital in respect of the New FA Common Shares was reduced by an amount equal to the entire amount of the BCo Note Cash Payment received by New FA from BCo, as such amount may be adjusted as described in Paragraph 19, and, on the reduction, New FA distributed such amount to ACo (the “New FA Distribution”) in a single cash distribution made in respect of all the issued and outstanding New FA Common Shares.

The resolution of the board of directors of New FA authorizing the New FA Distribution specifies that the amount of the New FA Distribution is subject to an adjustment clause, which will adjust the amount of the New FA Distribution upward or downward depending on any adjustment to the amount of the BCo Note Cash Payment, as described in Paragraph 19.

ACo will elect in writing pursuant to paragraph 5901(2)(b) of the Regulations, within the time prescribed therein, to treat the portion of the New FA Distribution that would otherwise have been deemed by subsection 5901(1) of the Regulations to have been paid out of the exempt surplus, hybrid surplus, or taxable surplus of New FA to instead be deemed to have been paid out of New FA’s pre-acquisition surplus.

PROPOSED TRANSACTION

21.   On a date after the completion of the Subject Transactions, New FA will be liquidated and dissolved. On the liquidation and dissolution, the property of New FA (consisting materially of the rights of New FA to receive an adjustment payment under the BCo Note and in respect of the New FA Distribution) will be transferred to ACo in consideration for ACo assuming the obligations of New FA (consisting materially of the obligations of New FA to make an adjustment payment under the BCo Note and in respect of the New FA Distribution).

ADDITIONAL INFORMATION

22.   The Subject Transactions in Paragraphs 16 to 20 took place in the above-noted sequence on XXXXXXXXXX.

23.   ACo controls each of BCo, FA1 and New FA through its direct or indirect shareholding interest in them. Consequently, each of these corporations is related to ACo and to each other under subparagraph 251(2)(b)(i) or 251(2)(c)(i).

24.   Immediately before the time of the transfer by ACo of its FA1 Shares to New FA, as described in Paragraph 16, all or substantially all of the property of FA1 constituted excluded property of FA1.

25.   ACo’s transfer of its FA1 Shares to New FA, as described in Paragraph 16, is not part of a transaction or event or a series of transactions or events the purpose of which is to dispose of the FA1 Shares to a person or partnership that, immediately after the transaction, event or series, will be a person or partnership (other than a foreign affiliate of ACo in respect of which ACo has a qualifying interest (within the meaning assigned by paragraph 95(2)(m)) at the time of the transaction or event or throughout the series, as the case may be) with whom ACo is dealing at arm's length.

26.   At the time of the transfer by ACo of its FA1 Shares to New FA, as described in Paragraph 16, the ACB to ACo of its FA1 Shares was not greater than the amount that would, absent subsection 85.1(3), be ACo’s proceeds of disposition of such FA1 Shares.

27.   The Transfer Amount was significantly less than the aggregate FMV of the FA1 Shares transferred by New FA to BCo, as described in Paragraph 17, at the time of the transfer.

28.   ACo may undertake transactions similar to the Subject Transactions and the Proposed Transaction in future years to transfer to BCo other subsidiaries with direct or indirect operations in Country A XXXXXXXXXX.

29.   ACo will not, as part of a series of transactions or events that includes the Subject Transactions and the Proposed Transaction, acquire directly, in any manner whatever or by any means whatever, any of the FA1 Shares that are transferred by New FA to BCo, as described in Paragraph 17.

30.   XXXXXXXXXX

PURPOSE OF THE SUBJECT TRANSACTIONS AND THE PROPOSED TRANSACTION

31.   XXXXXXXXXX. The purpose of the Subject Transactions and the Proposed Transaction is to transfer the ownership of FA1 to BCo in order to permit ACo XXXXXXXXXX in a manner that is neutral from a tax perspective.

32.   The purpose for the transfer by New FA of its FA1 Shares to BCo, as described in Paragraph 17, occurring at the Transfer Amount as opposed to occurring at their FMV, was not to confer a benefit on a person, but rather to address certain policy concerns of the CRA by restricting BCo’s aggregate ACB of its FA1 Shares to the Transfer Amount.

RULINGS PROVIDED

Provided that the preceding statements constitute a complete and accurate disclosure of all the relevant Facts, Subject Transactions, Proposed Transaction, Additional Information and the purpose of the Subject Transactions and Proposed Transaction, that the Proposed Transaction is completed in the manner described above, and that there are no other transactions that may be relevant to the rulings given, we rule that:

A.    Provided that the FA1 Shares constituted capital property to ACo, the provisions of paragraphs 85.1(3)(b), (c) and (d) applied to the transfer by ACo of its FA1 Shares to New FA, as described in Paragraph 16, such that:

(a)   the cost to ACo of the New FA Shares issued as consideration for the FA1 Shares will, pursuant to paragraph 85.1(3)(b), be equal to the ACB of the FA1 Shares to ACo immediately before their disposition;

(b)   ACo’s proceeds of disposition for the FA1 Shares will, pursuant to paragraph 85.1(3)(c), be equal to ACo’s cost of the New FA Shares; and

(c)   New FA’s cost of the FA1 Shares will, pursuant to paragraph 85.1(3)(d), be equal to ACo’s proceeds of disposition of the FA1 Shares.

B.    The transfer by ACo of its FA1 Shares to New FA, as described in Paragraph 16, and the transfer by New FA of its FA1 Shares to BCo, as described in Paragraph 17, did not, in and by themselves, cause such FA1 Shares that were capital property to ACo immediately before the first such transfer not to be capital property to New FA during the period that it held such shares.

C.    To the extent that the Transfer Amount was less than the aggregate FMV of the FA1 Shares at the time of the transfer by New FA of such FA1 Shares to BCo, as described in Paragraph 17, paragraph 69(1)(b) applied to deem New FA to receive proceeds of disposition of its FA1 Shares equal to such FMV.

D.    To the extent of any capital gain (determined without the application of subsection 93(1)) realized by New FA from the disposition by New FA of its FA1 Shares to BCo, as described in Paragraph 17:

(a)   subsections 93(1), (1.1) and (1.11) and the relevant Regulations applied to cause the amount prescribed under subsection 5902(6) of the Regulations, to be treated as a dividend received by New FA from FA1 immediately before the disposition and not to be proceeds of disposition of such FA1 Shares; and

(b)   provided that the FA1 Shares were excluded property of New FA at the time of the disposition, the amount of any capital gain (determined after the application of subsection 93(1)) from the disposition of such shares would not have been included in the FAPI of New FA.

E.    With respect to the New FA Distribution:

(a)   the New FA Distribution was deemed by subsection 90(2) to be a dividend paid by New FA to ACo, and, for greater certainty, was not recharacterized as interest for any purpose of the Act pursuant to subsection 258(3) or (5);

(b)   provided that ACo elects in writing pursuant to paragraph 5901(2)(b) within the time prescribed therein, the portion of the New FA Distribution that would otherwise have been deemed by subsection 5901(1) of the Regulations to have been paid out of the exempt surplus, hybrid surplus, or taxable surplus of New FA will instead be deemed to have been paid out of New FA’s pre-acquisition surplus in respect of ACo;

(c)   the amount of such dividend was deductible by ACo pursuant to paragraph 113(1)(d) in computing its taxable income for the taxation year in which the New FA Distribution was received by ACo;

(d)   subparagraph 53(2)(b)(i) and subsection 92(2) applied at the time of the New FA Distribution to reduce the ACB to ACo of its New FA Common Shares by the amount of the New FA Distribution; and

(e)   to the extent the reduction in the ACB of the New FA Common Shares owned by ACo, as described in paragraph (d) above, caused there to be an excess, as described in subsection 40(3), subsections 40(3), 93(1), 93(1.1) and 93(1.11) and the relevant Regulations caused:

(i)   the amount, as is prescribed under subsection 5902(6) of the Regulations, to be treated as a dividend received by ACo from New FA immediately before the time of the New FA Distribution; and

(ii)  the portion of the excess that was not treated as a dividend was deemed by subsection 93(1) to be a capital gain of ACo from the disposition of the New FA Common Shares owned by ACo at that time.

F.    The provisions of subsections 15(1), 56(2), 69(4) and 246(1) did not apply to the transfer by New FA of all of its FA1 Shares to BCo, as described in Paragraph 17.

G.    The provisions of subsection 245(2) will not be applied as a result of the Subject Transactions and Proposed Transaction, in and by themselves, to redetermine the tax consequences confirmed in any of the rulings given above.

COMMENTS

The above rulings, which are based on the Act and the Income Tax Regulations in their present form and which do not take into account any proposed amendments thereto, are given subject to the general limitations and qualifications set out in Information Circular 70-6R6 dated August 29, 2014, and are binding on the CRA provided that the Proposed Transaction is completed by XXXXXXXXXX.

Nothing in this letter should be construed as implying that the CRA has agreed to, reviewed or has made any determination in respect of any tax consequences relating to the Facts, Subject Transactions and Proposed Transaction described herein other than those specifically described in the rulings given above and in particular, without limiting the generality of the foregoing, in respect of:

(a)   the amount of the FMV, ACB, RCB, cost or capital cost of any property referred to herein, or whether any such property is capital property or excluded property; or

(b)   any surplus balances of foreign affiliates referred to herein.

Yours truly,

XXXXXXXXXX
Section Manager
for Division Director
International Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch

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