2017-0711911R3 loss consolidation ruling

Principal Issues: Whether the loss consolidation arrangement is acceptable?

Position: Yes.

Reasons: The proposed transactions conform to our requirements for loss consolidation arrangements.

Author: XXXXXXXXXX
Section: 20(1)(c) 55(2)

XXXXXXXXXX                                                                                  2017-071191

XXXXXXXXXX, 2017

Dear XXXXXXXXXX

Re:   Advance Income Tax Ruling Request
         XXXXXXXXXX

We are writing in response to your letter of XXXXXXXXXX, in which you requested an advance income tax ruling on behalf of the above-noted taxpayers (the “Taxpayers”).  We also acknowledge the information provided in various emails.

To the best of your knowledge and that of the Taxpayers, none of the issues involved in the ruling request is:

i.    in a previously filed tax return of any of the Taxpayers or a related person;

ii.   being considered by a tax services office or a tax centre in connection with a previously filed tax return of any of the Taxpayers or a related person;

iii.  under objection by any of the Taxpayers or a related person;

iv.   the subject of a current or completed court process involving the Taxpayers or a related person; or

v.    the subject of a ruling request previously considered by the Directorate.

The Taxpayers have also confirmed that the proposed transactions described herein will not result in the Taxpayers or any person related to the Taxpayers being unable to pay any of their outstanding tax liabilities.

Unless specified otherwise, all statutory references herein are to provisions or parts of the Income Tax Act (Canada), R.S.C. 1985 (5th Supp.) c. 1, as amended to the date hereof (the “Act”) and all references to monetary amounts are in Canadian dollars. This document is based solely on the facts described below. Any documentation submitted with your request does not form part of the facts except as expressly referred to herein, and any references thereto are otherwise provided solely for the convenience of the reader.

DEFINITIONS:

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

“Aco” means XXXXXXXXXX, a corporation governed by the CBCA. Aco is a holding company that primarily holds XXXXXXXXXX indirectly through Holdco. The shares of Aco are publically traded on the XXXXXXXXXX Stock Exchange under the symbol XXXXXXXXXX;

“Aco Loan” means the loan made to Aco as described in Paragraph 17;

“Aco Tax Attributes” means certain deductions from income that have not been claimed by Aco, including interest expense on the Issued Public Debt, and the unclaimed capital cost allowance as described in Paragraph 3;

“Act” means the Income Tax Act, R.S.C. 1985 (5th Supp.) c.1, as amended to the date hereof, and unless otherwise stated, every reference herein to a part, section, subsection, paragraph, subparagraph or clause is a reference to the relevant provision of the Act;

“Affiliated Person” has the meaning of affiliated person assigned by subsection 251.1(1);

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

“Canadian Corporation” has the meaning assigned by subsection 89(1);

“CBCA” means the Canada Business Corporations Act;

“CFA” means a “Controlled Foreign Affiliate” and has the meaning assigned by subsection 95(1);

“CRA” means the Canada Revenue Agency;

“Daylight Loan” means the loan described in Paragraph 14;

“FAPI” means “foreign accrual property income” and has the meaning assigned by subsection 95(1);

“FMV” means fair market value;

“Holdco” means XXXXXXXXXX, a corporation incorporated under the CBCA and is a Subsidiary Wholly-owned Corporation of Aco;

“Bco” means XXXXXXXXXX, a corporation incorporated pursuant to XXXXXXXXXX and operates under the provisions of the XXXXXXXXXX and is a Subsidiary Wholly-owned Corporation of Aco and a CFA of Aco;

“Profitco” means XXXXXXXXXX, a corporation incorporated under the XXXXXXXXXX and is a Subsidiary Wholly-owned Corporation of Holdco. XXXXXXXXXX;

“Issued Public Debt” means the issued public debts described in Paragraph 3;

“Lossco1” means a Subsidiary Wholly-owned Corporation to be formed by Holdco. Lossco1 will be incorporated under the CBCA as part of the Proposed Transactions;

“Lossco2” means a Subsidiary Wholly-owned Corporation to be formed by Holdco. Lossco2 will be incorporated under the CBCA as part of the Proposed Transactions;

“Lossco1 Loan” means the loan made to Lossco1 as described in Paragraph 15;

“New Daylight Loan” means the loan described in Paragraph 22(b);

“Newco1” means XXXXXXXXXX, a corporation incorporated under the CBCA and a Subsidiary Wholly-owned Corporation of Aco;

“Newco2” means a Subsidiary Wholly-owned Corporation to be formed by Aco.  Newco2 will be incorporated under the CBCA as part of the Proposed Transactions;

“Newco1 Preferred Shares” means the preferred shares described in Paragraph 16;

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

“Paragraph” refers to a numbered paragraph in this letter;

“Proposed Transactions” means the transactions described in Paragraphs 12 to 26 herein;

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

XXXXXXXXXX;

“Subsidiary Wholly-owned Corporation” has the meaning assigned by subsection 248(1); and

“TCC” means “taxable Canadian corporation” as defined by subsection 89(1).

FACTS:

1.    Aco is a holding company that holds certain XXXXXXXXXX corporations. Aco is a XXXXXXXXXX entity that generally does not have any taxable income, other than its FAPI from its CFA, Bco, XXXXXXXXXX. Aco does not have any other significant activity aside from performing certain centralized functions for the Aco group such as XXXXXXXXXX Aco does recover most of its costs from its subsidiaries, excluding its interest expense on the Issued Public Debt, but it does not mark up the other costs.  Moreover, it does not have any significant independent sources of income, other than dividends from subsidiaries and the FAPI from Bco. Aco’s address is XXXXXXXXXX. Aco’s taxation centre is the XXXXXXXXXX Tax Centre and its Tax Services Office is XXXXXXXXXX Tax Services Office. Its business number is XXXXXXXXXX.

2.    Aco’s year end is XXXXXXXXXX. As of XXXXXXXXXX, Aco had unclaimed capital cost allowance (“CCA”) of $XXXXXXXXXX.

3.    As of XXXXXXXXXX, Aco has Issued Public Debt of $XXXXXXXXXX for the financing of the operations of the Aco group.  XXXXXXXXXX. As of XXXXXXXXXX, Aco will not have any undeducted non-capital losses from prior taxation years. In addition, after XXXXXXXXXX, and until the Issued Public Debt is partially repaid, Aco anticipates it will incur interest expense on the Issued Public Debt that cannot be fully sheltered with the FAPI from Bco so that Aco estimates that it would have a non-capital loss of $XXXXXXXXXX as of XXXXXXXXXX. The unclaimed CCA, described in paragraph 2, and interest expense together are “Aco Tax Attributes”. The Aco Tax Attributes are not restricted under subsection 111(5) of the Act.

4.    Aco had permanent establishments in XXXXXXXXXX for its XXXXXXXXXX taxation year. The provincial allocation to each of these provinces was approximately XXXXXXXXXX, respectively. Aco expects the XXXXXXXXXX taxable income allocation to be similar.

5.    Profitco generates taxable income and its year end is XXXXXXXXXX. XXXXXXXXXX. Profitco’s address is XXXXXXXXXX. Profitco’s taxation centre is the XXXXXXXXXX Tax Centre and its Tax Services Office is XXXXXXXXXX Tax Services Office. Its business number is XXXXXXXXXX.

6.    Profitco had permanent establishments in XXXXXXXXXX for its XXXXXXXXXX taxation year. The allocation to XXXXXXXXXX was approximately XXXXXXXXXX, respectively. XXXXXXXXXX Profitco expects the XXXXXXXXXX taxable income allocation to be similar.

7.    The share capital of Newco1 consists of XXXXXXXXXX issued and outstanding common shares, without par value, voting and participating.  Newco1 is authorized to issue an unlimited amount of preferred shares. Newco1’s address is XXXXXXXXXX. Newco1’s taxation centre is the XXXXXXXXXX Tax Centre and its Tax Services Office is XXXXXXXXXX Tax Services Office. Its business number is XXXXXXXXXX.

8.    As of XXXXXXXXXX, all issued and outstanding shares of Profitco are common shares owned by Holdco.  The authorized share capital of Profitco consists of:

An unlimited number of common shares without par value, voting.

*     Class A Preferred shares, with a par value of XXXXXXXXXX, voting, redeemable at the option of the Profitco at the value of the consideration received. Non-cumulative annual dividend at XXXXXXXXXX of the prime rate. Dividends paid on Class A Preferred shares have preference over dividends paid on common shares;

*     Class C Preferred shares, with a par value of XXXXXXXXXX, non-voting, redeemable for an amount equal to the fair market value of the consideration received. They are retractable for an amount equal to the redemption amount;

*     Class D Preferred shares, with no par value, issuable in one or more series, entitled to dividends after Class A Preferred Shares but before common shares; and

*     Class E Preferred shares, with no par value, issuable in one or more series, entitled to dividends after Class A Preferred Shares and Class D Preferred Shares but before common shares.

9.    As of XXXXXXXXXX, all issued and outstanding shares of Holdco are Class A voting shares owned by Aco. Holdco’s address is XXXXXXXXXX. Holdco’s taxation centre is the XXXXXXXXXX Tax Centre and its Tax Services Office is XXXXXXXXXX Tax Services Office. Its business number is XXXXXXXXXX.

10.   Aco, Profitco, Holdco and Newco1 are each a XXXXXXXXXX and a TCC.

11.   Lossco1, Lossco2 and Newco2, once formed, will each be a XXXXXXXXXX and a TCC.

PROPOSED TRANSACTIONS

12.   Holdco will incorporate Lossco1 under the CBCA. The taxation year-end of Lossco1 will be XXXXXXXXXX.  The activities of Lossco1 will be limited to the activities described in the Proposed Transactions, including the investing of the proceeds received from the Lossco1 Loan from Aco (as described in Paragraph 15 below). Such Lossco1 loan proceeds will be invested in the Newco1 Preferred Shares, as described in Paragraph 16 below.

The authorized share capital of Lossco1 will consist of an unlimited number of common shares.

The common shares of Lossco1 will be without par value and voting (XXXXXXXXXX per share).  The holders of common shares will be entitled to dividends at the discretion of the directors, and will be entitled to receive the remaining property of the corporation upon its winding-up or dissolution.

13.   Lossco1 will issue common shares of its capital stock to Holdco for an amount no greater than $XXXXXXXXXX.

14.   Aco will borrow $XXXXXXXXXX on a “daylight loan” basis from an arm’s length financial institution (the “Daylight Loan”) on arm’s length commercial terms customary for this type of loan.  The amount of the Daylight Loan will not exceed the borrowing capacity of the Aco group.

15.   Aco will use the proceeds of the Daylight Loan to make a loan of the same amount to Lossco1 (the “Lossco1 Loan”). Simple interest will accrue on the Lossco1 Loan and will be calculated at a rate that would not exceed a reasonable commercial arm’s length rate. The interest rate will be determined at the time the Proposed Transactions will be implemented and is expected to be approximately XXXXXXXXXX. The Lossco1 Loan will be payable on demand and the interest will be payable periodically and at least annually.

16.   Lossco1 will use the proceeds of the Lossco1 Loan to subscribe for preferred shares of Newco1 (the “Newco1 Preferred Shares”).

The Newco1 Preferred Shares will be without par value and non-voting. The Newco1 Preferred Shares will be redeemable and retractable for a redemption price equal to the amount contributed (plus any accrued but unpaid dividends), which should correspond to the same amount of the Lossco1 Loan (if the accrued but unpaid dividends were excluded). The PUC and the FMV of the Newco1 Preferred Shares will be equal to the amount contributed.

Lossco1 will be entitled to cumulative dividends on the Newco1 Preferred Shares, calculated daily by reference to the redemption/retraction price of the Newco1 Preferred Shares at a rate equal to the interest rate on the Lossco1 Loan plus a small spread (XXXXXXXXXX basis points).  The dividends on the Newco1 Preferred Shares will be payable periodically. Any accrued but unpaid dividends shall be payable on the redemption of the Newco1 Preferred Shares.

The amount of dividends on the Newco1 Preferred Shares held by Lossco1 will be sufficient to permit Lossco1 to realize a profit on its investment activity, after the deduction of all its expenses (not only its interest expense).

17.   Newco1 will use the proceeds received from the Newco1 Preferred Shares subscription in Paragraph 16 to make an interest-free loan to Aco of the same amount (the “Aco Loan”). The Aco Loan will be payable on demand.

18.   Aco will use the proceeds received from the Aco Loan to repay the Daylight Loan.

19.   While the Lossco1 Loan is outstanding, Aco will, at least annually, make a contribution of capital to Newco1 in an amount equal to the dividend payable by Newco1 on the Newco1 Preferred Shares held by Lossco1. No shares will be issued by Newco1 with respect to these contributions of capital and no amount will be added to Newco1’s stated capital accounts. The amount of each contribution of capital will be recorded by Newco1 as contributed surplus for accounting purposes. The contributions of capital will not be treated as income of Newco1 pursuant to generally accepted accounting principles. Aco will not claim any deduction in computing income in respect of any capital contributions made to Newco1.

20.   Upon receipt of the contributions of capital described in Paragraph 19 above, Newco1 will use the amounts received to pay dividends to Lossco1 equal to the amount of the dividends payable on the Newco1 Preferred Shares.

21.   Lossco1 will use most of the amounts received as dividends from Newco1 to pay interest to Aco on the Lossco1 Loan.

22.   The following transactions will occur prior to XXXXXXXXXX in order to unwind the loss consolidation arrangement:

(a)   Aco will make a contribution of capital to Newco1 in an amount equal to the amount of any accrued and unpaid dividends on the Newco1 Preferred Shares held by Lossco1. No shares will be issued by Newco1 and no amount will be added to its stated capital account in respect of the contribution.  The amount of this contribution of capital, if any, will be recorded as contributed surplus for accounting purposes. The contribution of capital, if any, will not be income of Newco1 pursuant to generally accepted accounting principles.

(b)   Aco will borrow an amount equal to the amount outstanding on the Aco Loan on a “daylight loan” basis from an arm’s length financial institution (the “New Daylight Loan”). Aco will use these funds to repay the Aco Loan to Newco1.

(c)   Newco1 will use the contribution of capital from Aco described in Paragraph (a) above and the funds received from Aco on the repayment of the Aco Loan described in Paragraph (b) above to redeem the issued and outstanding Newco1 Preferred Shares held by Lossco1.

(d)   Lossco1 will use most of the funds received from the redemption of the Newco1 Preferred shares received in Paragraph (c) above to repay the Lossco1 Loan and any unpaid interest thereon.

(e)   Aco will use the funds received from Lossco1 on the repayment of the Lossco1 Loan to repay the New Daylight Loan.

23.   Immediately after the Proposed Transaction described in Paragraph 22 above and before XXXXXXXXXX, Holdco will transfer to Profitco all of its common shares of Lossco1 in exchange for common shares of Profitco. Holdco and Profitco will jointly elect in a prescribed form and within the time limit referred to in subsection 85(6), to have the provisions of subsection 85(1) apply to the transfer. The agreed amount in respect of the Lossco1 common shares transferred will be the lesser of the FMV of those shares and $XXXXXXXXXX, being the ACB of such shares. Profitco will add to its stated capital account in respect of the common shares issued to Holdco an amount equal to the PUC to Holdco of the commons shares of Lossco1.  The PUC to Holdco of the common shares of Lossco1, which will be $XXXXXXXXXX.

24.   Shortly after the Proposed Transactions described in Paragraphs 22 and 23 above and before XXXXXXXXXX, Profitco will cause Lossco1 to be wound-up in such a manner that all the assets of Lossco1 will be acquired by Profitco and all of the liabilities, if any, of Lossco1 will be assumed by Profitco. It is expected that subsection 88(1) will apply to the wind-up of Lossco1. Lossco1 will be formally dissolved before the end of the first taxation year of Profitco commencing after the commencement of the winding-up of Lossco1. Lossco1 will file articles of dissolution with the appropriate corporate registry within a reasonable time after the winding-up resolution is passed.

25.   Shortly after the Proposed Transactions described in Paragraph 22 and 23 above and before XXXXXXXXXX, Aco will cause Newco1 to be wound-up in such a manner that all the assets of Newco1 will be acquired by Aco and all of the liabilities, if any, of Newco1 will be assumed by Aco. It is expected that subsection 88(1) will apply to the wind-up of Newco1. Newco1 should be legally dissolved within a short period of time. Newco1 will file articles of dissolution with the appropriate corporate registry within a reasonable time after the winding-up resolution is passed.

26.   After the windup of Lossco1 and Newco1, two new corporations (Newco2 and Lossco2) will be incorporated having the same characteristics as Newco1 and Lossco1. The above Proposed Transactions, with Newco2 and Lossco2 (instead of Newco1 and Lossco1) will be repeated in the XXXXXXXXXX taxation year in order to use the portion of the interest expense on the Issued Public Debt that cannot be otherwise sheltered with FAPI from Bco. Both Newco2 and Lossco2 will be wound up by XXXXXXXXXX.

Additional Information

27.   Lossco1 and Newco1 will not be used for any other purposes than those described in the Proposed Transactions. Aco will not claim, at any time, a capital loss in respect of its capital contribution in Lossco1 and Newco1. Also, Lossco1 and Newco1 will never be insolvent.

28.   After the Proposed Transactions described in Paragraphs 12 to 21, the FMV of the common shares of Lossco1 should be equal to the aggregate of (i) the value of the tax savings resulting from the use of the Aco Tax Attributes and (ii) any amount of cash held by Lossco1 net of any liability.

29.   Aco, Lossco1, Newco1 and Profitco, are affiliated persons and are related to each other and will continue to be affiliated and related to each other throughout the Proposed Transactions.

30.   At no time during the implementation of the Proposed Transactions will the Newco1 Preferred Shares be:

(a)   the subject of any undertaking that is referred to in subsection 112(2.2) as a “guarantee agreement”;

(b)   the subject of a “dividend rental arrangement” as contemplated in subsection 112(2.3) and as defined in subsection 248(1);

(c)   the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or

(d)   issued for consideration that is or includes:

(i)   an obligation of the type described in subparagraph 112(2.4)(b)(i); or

(ii)  any right of the type described in subparagraph 112(2.4)(b)(ii).

31.   At the time of the Proposed Transactions:

(a) Aco will have the financial capacity, including accessing its leverage capacity, to make the capital contributions to Newco1 as described in Paragraphs 19 and 22(a) above; and

(b)   Newco1 will have the financial capacity to satisfy the applicable solvency test required to pay the dividends on the Newco1 Preferred Shares and to redeem the Newco1 Preferred Shares as described in Paragraphs 20 and 22(c) above.

32.   The sole purpose for the acquisition of the Newco1 Preferred Shares is to execute the Proposed Transactions. Thus, the Newco1 Preferred Shares will not be acquired in the ordinary course of the business that would be carried by Lossco1.

33.   The dividends paid or payable on the Newco1 Preferred Shares to Lossco1, as described in Paragraph 20 above, have no purpose other than the purpose described under the Proposed Transactions.

34.   XXXXXXXXXX.

35.   The Proposed Transactions will be legally effective.

36.   At all times, Aco will have the financial capacity to make the relevant capital contributions to Newco1, as described in Paragraph 19.

37.   At all times, Lossco1 will have the solvency and liquidity to service the Lossco1 Loan.

38.   At the time it is required to pay the dividends on the Newco1 Preferred Shares, as described in Paragraph 20, Newco1 will have the financial capacity to satisfy the applicable solvency and liquidity test under the CBCA (having regard to the contributions of capital received from Aco).

Purpose of the Proposed Transactions

The purpose of the Proposed Transactions is to consolidate Profitco’s income with Aco’s losses that would have been realized if Aco had deducted the full amount of capital cost allowance and interest expense. The loss consolidation will be achieved by a series of transactions, including the creation of Non-capital Losses in Lossco1, and the subsequent utilization of the Non-capital Losses created in Lossco1 by Profitco. XXXXXXXXXX.

The purpose of both the payment and the receipt of the dividends on the Newco1 Preferred Shares to Lossco1, as described in paragraph 33, is to provide a reasonable return on the Newco1 Preferred Shares issued by Newco1 to Lossco1 and to fund the interest payments on the Lossco1 Loan. Furthermore, the purpose of the dividends is not to reduce the fair market value or capital gain of any share, nor to increase the total cost amounts of properties of Profitco.

RULINGS PROVIDED

Provided that

(a)   the preceding statements constitute a complete and accurate disclosure of all of the relevant facts, proposed transactions and the purposes of the proposed transactions,

(b)   the Proposed Transactions are completed in the manner described above, and

(c)   there are no other transactions which may be relevant to the rulings requested,

we rule that:

A.    Provided that Lossco1 has a legal obligation to pay interest on the Lossco1 Loan, and the Newco1 Preferred Shares continue to be held by Lossco1 for the purpose of gaining or producing income therefrom, Lossco1 will be entitled pursuant to paragraph 20(1)(c), to deduct in computing its income for a taxation year, the lesser of: (i) the interest paid or payable in respect of the Lossco1 Loan for that taxation year (depending on the method regularly followed by Lossco1 in computing its income for the purposes of the Act); and (ii) a reasonable amount in respect thereof.

B.    The dividends received (or deemed to be received) by Lossco1 in respect of the Newco1 Preferred Shares in a taxation year will be taxable dividends that will be deductible in computing the taxable income of Lossco1 for the taxation year in which the dividends are received pursuant to subsection 112(1), and for greater certainty, such deductions will not be precluded by any of subsections 112(2.1), 112(2.2), 112(2.3) or 112(2.4).

C.    Provided that the purpose of the dividends, described in Ruling B that are received by Lossco1 on the Newco1 Preferred Shares, is as described in the “Purposes of the Proposed Transactions” above and the Proposed Transactions are undertaken in the manner described above, subsection 55(2) will not apply in respect of the dividends described in Paragraph 20.

D.    No amount will be included in the income of Newco1 pursuant to section 9 or paragraphs 12(1)(c) or 12(1)(x) in respect of the contributions of capital made by Aco as described in Paragraphs 19 and 22(a) above.

E.    The provisions of subsections 15(1), 56(2), and 246(1) will not apply as a result of entering into the Proposed Transactions, in and by themselves.

F.    Provided that the requirements of paragraphs 88(1.1)(a) and (b) are satisfied, subsection 88(1.1) will apply after the winding-up of Lossco1 into Profitco, as described in paragraph 24, to permit Profitco to deduct the Non-capital Loss of Lossco1 in computing its taxable income or tax payable under Part IV for any taxation year commencing after the commencement of the winding-up, subject to the limitations in Paragraph 88(1.1)(e) and section 111.

G.    Subsection 245(2) will not be applied as a result of entering into the Proposed Transactions, in and by themselves, to re-determine the tax consequences confirmed in the rulings given.

The above rulings are given subject to the general limitations and qualifications set out in Information Circular 70-6R7 dated April 22, 2016, and are binding on the CRA provided that the Proposed Transactions as described in Paragraphs 12 to 21 are entered into on or before XXXXXXXXXX; the Proposed Transactions related to the wind-up as described in Paragraphs 22 to 25 are entered into on or before XXXXXXXXXX; and the Proposed Transactions as described in Paragraph 26 are entered into on or before XXXXXXXXXX.

The above rulings are based on the Act in its present form and do not take into account the effect of any proposed amendments to the Act which, if enacted, could have an effect on the rulings provided herein.

COMMENTS

Nothing in this letter should be construed as implying that the CRA has agreed to, reviewed or has made any determination in respect of:

(a)   the fair market value or adjusted cost base of any property or the paid-up capital of any shares referred to herein;
(b)   the reasonableness or fair market value of any fees or expenditures referred to herein;
(c)   the amount of any non-capital loss, net capital loss or any other amount of any corporation referred to herein;
(d)   the provincial income tax implications relating to the allocation of income and expenses under the Proposed Transactions;
(e)   the application or non-application of a general anti-avoidance provision of any province; and
(f)   any tax consequences relating to the Facts and Proposed Transactions described herein, other than those specifically described in the rulings given above.

Yours sincerely,

XXXXXXXXXX
for Director
Partnerships and Corporate Financing Section
Reorganizations Division
Income Tax Rulings Directorate

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