2023-0961611R3 Loss consolidation arrangement

Principal Issues: Whether a loss consolidation arrangement involving a loan to buy preferred shares for the purposes of earning income would meet the CRA's requirement for acceptable loss consolidation transactions.

Position: Yes.

Reasons: Consistent with previous rulings.

Author: XXXXXXXXXX
Section: 20(1)(c); 112(1); 88(1); 245(1)

XXXXXXXXXX                                                              2023-096161


XXXXXXXXXX, 2023


Dear XXXXXXXXXX:

Re: Advance Income Tax Ruling Request
XXXXXXXXXX

We are writing in response to your letter of January 26, 2023, wherein you requested an advance income tax ruling on behalf of the above-referenced taxpayers (the “Taxpayers”).

To the best of your knowledge and that of the taxpayers involved, none of the proposed transactions or issues involved in this Ruling request are the same as or substantially similar to transactions or issues that are:

i. in a previously filed tax return of the taxpayers or a related person and:

A. being considered by the CRA in connection with such return;

B. under objection by the taxpayers or a related person; or

C. the subject of a current or completed court process involving the taxpayers or a related person; or

ii. the subject of a Ruling request previously considered by the Income Tax Rulings Directorate.

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

In this letter, the following terms or expressions have the meanings specified:

XXXXXXXXXX;

“ACo” is a corporation to be incorporated under the BCA as described in Paragraph 10;

“ACo Common Shares” has the meaning assigned in Paragraph 10;

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

“affiliated persons” has the meaning assigned by section 251.1, read without reference to
the definition of “controlled” in subsection 251.1(3);

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

“Agreeing Province” means a province that has entered into an agreement with the Government of Canada under which the Government of Canada will collect taxes payable under the income tax statute of that province and will make payments to that province in respect of the taxes so collected;

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

“BCA” means the XXXXXXXXXX, as amended;

“CRA” means the Canada Revenue Agency;

“dividend rental arrangement” has the meaning assigned by subsection 248(1);

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

“excepted dividend” has the meaning assigned by section 187.1;

“excluded dividend” has the meaning assigned by subsection 191(1);

“fair market value” means the highest price available in an open and unrestricted market between informed and prudent parties dealing at arm's length and under no compulsion to act, expressed in terms of cash;

XXXXXXXXXX;

“General Anti-avoidance Provision of an Agreeing Province” means:

XXXXXXXXXX;

“guarantee agreement” has the meaning assigned by subsection 112(2.2);

XXXXXXXXXX;

“Loan 1” means a non-interest bearing loan made by Parent to Lossco, the principal amount of which will equal the principal amount of Parent Loan;

“Loan 2” means an interest bearing loan made by Lossco to ACo, the principal amount of which will equal the principal amount of Parent Loan. Loan 2 will bear interest at an annual rate, based on market conditions at the time the loan is granted, which will be an arm’s length, commercial interest rate in these circumstances. Interest on Loan 2 will be payable at the earlier of XXXXXXXXXX of each year or such time that Loan 2 is repaid;

“Loan 3” means a non-interest bearing loan made by Newco to Lossco, the principal amount of which will equal the principal amount of Parent Loan;

“Lossco” means XXXXXXXXXX;

“Lossco Subsidiaries” means Opco, XXXXXXXXXX, the wholly owned subsidiaries of those corporations and an investment in XXXXXXXXXX;

“Newco” is a corporation to be incorporated under the BCA, as described in Paragraph 11;

“Newco Note” has the meaning assigned in Paragraph 24(a);

“Newco Preferred Shares” means the preferred shares to be issued by Newco described in Paragraph 12;

“non-capital loss” has the meaning assigned by subsection 111(8);

“Opco” means XXXXXXXXXX;

“Opco Common Shares” has the meaning assigned in Paragraph 25;

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

“Paragraph” means a numbered paragraph of this letter;

“Parent” means XXXXXXXXXX;

“Parent Loan” means a loan made by an unrelated arm’s length financial institution to Parent, the principal amount of which will be approximately $XXXXXXXXXX as described in Paragraph 13. The exact principal amount of Parent Loan will be finalized when the Proposed Transactions are implemented;

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

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

“Proposed Transactions” means the transactions described in Paragraphs 10 to 29;

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

“related persons” has the meaning assigned by subsection 251(2);

“XXXXXXXXXX” has the meaning assigned by subsection 55(1);

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

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

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

“taxation year” has the meaning in subsection 249(1); and

“term preferred share” has the meaning assigned by subsection 248(1).

FACTS

1. Parent was incorporated under the XXXXXXXXXX and is a taxable Canadian corporation but deemed not to be a private corporation except for certain purposes of the Act. The taxation year of Parent ends on XXXXXXXXXX. The authorized capital of Parent consists XXXXXXXXXX. The preference shares are held by XXXXXXXXXX. Parent’s registered address and head office address is XXXXXXXXXX. Its Taxation Centre is the XXXXXXXXXX.

2. Lossco was continued under the BCA and is a private corporation and a taxable Canadian corporation. The taxation year of Lossco ends on XXXXXXXXXX. Lossco is a wholly-owned subsidiary of Parent and acts as a holding company. Lossco’s assets in Canada include the Lossco Subsidiaries. XXXXXXXXXX. While Lossco does recover some of its costs from the Lossco Subsidiaries, it does not mark up these costs and it does not currently have significant independent sources of income. Lossco’s registered address and head office address is XXXXXXXXXX.

3. Parent owns all of the common shares, all of the Class A special shares and all of the Class A Preference Shares of Lossco, representing all of the issued and outstanding share capital of Lossco.

4. If the Proposed Transactions were not undertaken in its XXXXXXXXXX taxation year, Lossco's estimated non-capital loss carry-forward at the end of its XXXXXXXXXX taxation year would be $XXXXXXXXXX. The following are the actual and estimated non-capital losses of Lossco for the taxation years of XXXXXXXXXX:

XXXXXXXXXX

5. Lossco expects that it will continue to incur non-capital losses because of interest-bearing debt obligations that it has outstanding. Lossco's non-capital losses are XXXXXXXXXX (i.e., Lossco only has a permanent establishment in the province of XXXXXXXXXX).

6. Opco was continued under the XXXXXXXXXX (Canada) and is a taxable Canadian corporation and a public corporation. The taxation year of Opco ends on XXXXXXXXXX. Opco is XXXXXXXXXX. Opco does not carry on any of its XXXXXXXXXX. The authorized capital of Opco includes both common shares and preferred shares that can be issued in one or more series. The common shares are the only shares with voting rights. XXXXXXXXXX. Opco’s registered address and head office address is XXXXXXXXXX.

7. Lossco owns all of the issued and outstanding voting common shares of Opco. XXXXXXXXXX.

8. Opco earned taxable income of $XXXXXXXXXX in fiscal XXXXXXXXXX. Opco expects to continue to earn significant taxable income in subsequent taxation years. Opco’s income is expected to be approximately XXXXXXXXXX.

9. XXXXXXXXXX.

PROPOSED TRANSACTIONS

10. Lossco will incorporate ACo under the BCA. ACo will be a private corporation and a taxable Canadian corporation. The taxation year of ACo will end on XXXXXXXXXX. Lossco will subscribe for common shares of ACo on incorporation for XXXXXXXXXX (the "ACo Common Shares"). Lossco will hold the ACo Common Shares as capital property. ACo will not carry on any business and its activities will be limited to investing the loan proceeds, received from Lossco, as described in Paragraph 15, in the Newco Preferred Shares, as described in Paragraph 16. ACo will not be a XXXXXXXXXX.

11. Lossco will incorporate Newco under the BCA. Newco will be a private corporation and a taxable Canadian corporation. The taxation year of Newco will end on XXXXXXXXXX. Lossco will subscribe for common shares of Newco for $XXXXXXXXXX. Newco will not carry on any business and its activities will be limited to investing the proceeds received upon the issuance of the Newco Preferred Shares to ACo, as described in Paragraph 16, in a non-interest bearing loan to Lossco, as described in Paragraph 17. Newco will not be a XXXXXXXXXX.

12. The authorized capital of Newco will consist of two classes of shares, common shares and preferred shares (the "Newco Preferred Shares"). Each Newco Preferred Share will be non-voting, redeemable and retractable for the amount for which it was issued. Dividends on the Newco Preferred Shares will accrue at a fixed rate on a daily basis and will be payable on the earliest of XXXXXXXXXX of each calendar year and the time at which any Newco Preferred Shares are redeemed or retracted. The dividend rate, expressed as a percentage of the amount for which a Newco Preferred Share was issued will be equal to the sum of XXXXXXXXXX% plus the interest rate on Loan 2.

13. Parent will borrow approximately $XXXXXXXXXX from an arm's length financial institution on a daylight loan basis (the "Parent Loan") on arm's-length commercial terms customary for that type of loan.

14. Parent will use the total proceeds received under Parent Loan to make Loan 1 to Lossco.

15. Lossco will use the total proceeds received under Loan 1 to make Loan 2 to ACo. The rate of interest is expected to be XXXXXXXXXX%. The rate of interest will be finalized when the Proposed Transactions are implemented.

16. ACo will use the total proceeds received from Loan 2 to subscribe for Newco Preferred Shares having an aggregate redemption amount and fair market value equal to the total amount of the subscription proceeds. The full amount of the subscription proceeds will be added to the stated capital of the Newco Preferred Shares and will form part of the permanent capital of Newco. The paid-up capital of each Newco Preferred Share issued will be equal to its redemption amount.

17. Newco will use the total proceeds received from the Newco Preferred Share subscriptions described in Paragraph 16 to make Loan 3 to Lossco.

18. Lossco will use the total proceeds received from Loan 3 to repay Loan 1.

19. Parent will use the total proceeds received from the repayment of Loan 1 to repay the Parent Loan.

20. All of the transactions described in Paragraphs 13 to 19 will take place on the same day.

21. On XXXXXXXXXX or such earlier date as Lossco, Newco and ACo agree, while Loan 2 is outstanding, Lossco will make a contribution of capital to Newco in an amount equal to the accrued dividends payable at that time, by Newco, on the Newco Preferred Shares held by ACo. No shares will be issued by Newco with respect to the contribution of capital and no amount will be added to the stated capital of any class of shares of Newco, or, for greater certainty, to the paid-up capital of any class of shares of Newco.

22. Upon receipt of the contribution capital, described in Paragraph 21, Newco will pay all accrued and unpaid dividends on the Newco Preferred Shares held by ACo.

23. Upon receipt of the payments of the dividends described in Paragraph 22, ACo will pay all accrued and unpaid interest due and payable on Loan 2 to Lossco, pursuant to the terms of Loan 2.

24. Immediately following the payment of interest described in Paragraph 23, the following transactions will occur to unwind the loss consolidation arrangement:

(a) Newco will redeem the Newco Preferred Shares held by ACo in consideration for a non-interest bearing promissory note issued by Newco (the "Newco Note"). The Newco Note will have a principal amount and fair market value equal to the redemption amount and fair market value of the Newco Preferred Shares redeemed;

(b) ACo will repay Loan 2 by assigning the Newco Note to Lossco in full satisfaction of the amount due under Loan 2. Loan 2 will be cancelled; and

(c) Lossco and Newco will agree to set off the amount due under Loan 3 against the amount due under the Newco Note as payment in full. The obligations under Loan 3 and the Newco Note will be cancelled.

25. Immediately following completion of the transactions described in Paragraphs 24(a) to 24(c), Lossco will transfer all of its ACo Common Shares to Opco for a purchase price equal to the fair market value of the ACo Common Shares which will be satisfied by the issue by Opco to Lossco of additional common shares of Opco (the "Opco Common Shares"). The Opco Common Shares issued to Lossco by Opco will have a fair market value equal to the fair market value of the ACo Common Shares transferred. The determination of the highest price of the ACo Common Shares available in an open and unrestricted market between informed and prudent parties dealing at arm's length and under no compulsion to act, expressed in terms of cash, will be made on the basis that the purchaser will be able to utilize ACo’s non-capital losses in the ordinary course in the same manner and within the same time period as Opco.

26. Lossco will jointly elect with Opco, in prescribed form and within the time allowed by subsection 85(6), to have the rules of subsection 85(1) apply to the transfer of the ACo Common Shares to Opco. The agreed amount in respect of the ACo Common Shares transferred will be the lesser of the fair market value of the ACo Common Shares transferred and XXXXXXXXXX, being the adjusted cost base of the ACo Common Shares owned by Lossco.

27. Opco will add to its stated capital account maintained for its common shares the agreed amount pursuant to subsection 85(1), as referred to in Paragraph 26. For greater certainty, the increase to the paid-up capital of the common shares of Opco will not exceed the maximum amount that could be added to the paid-up capital of such shares, having regard to subsection 85(2.1).

28. In the taxation year in which Opco acquires the ACo Common Shares described in Paragraph 25, Opco, as sole shareholder of ACo, will pass a resolution authorizing and requiring ACo to be wound up into Opco. In addition, a general conveyance of the assets of ACo and assumption of liabilities of ACo will be executed between Opco and ACo. ACo will file articles of dissolution with the appropriate Corporate Registry within a reasonable time after the winding-up resolution is passed. It is expected that ACo will be formerly dissolved before the end of the XXXXXXXXXX taxation year of Opco commencing after the commencement of the winding-up of ACo.

29. Immediately after the resolution to wind up ACo into Opco, Lossco, as sole shareholder of Newco, will pass a resolution authorizing and requiring Newco to be wound up into Lossco. In addition, a general conveyance of assets of Newco and assumption of liabilities of Newco will be executed between Lossco and Newco. Newco will file articles of dissolution with the appropriate Corporate Registry within a reasonable time after the winding-up resolution is passed.

ADDITIONAL INFORMATION

30. The Proposed Transactions will be legally effective.

31. At the time of the Proposed Transactions, Lossco will have the borrowing capacity to obtain a commercial loan, in an amount equal to the amount of Loan 1, directly from an arm's length financial institution and this borrowing will not cause Lossco to contravene its debt covenants. The Principal amount of the Parent Loan will not exceed Parent's borrowing capacity.

32. At the time of the Proposed Transactions, Lossco will have the financial capacity, including accessing its leverage capacity, to make the capital contributions to Newco described in Paragraph 21. Lossco may obtain the funds to make the capital contributions to Newco by borrowing from one or more of its affiliates or from an arm's-length financial institution as a daylight loan. Lossco will have the borrowing capacity to borrow the amount of the capital contributions from an arm's-length financial institution.

33. At the time it is required to pay the dividends on the Newco Preferred Shares, described in Paragraph 22, Newco will have the financial capacity to satisfy the applicable solvency test and liquidity test under the BCA.

34. Lossco and Opco are affiliated persons and are related persons. ACo and Newco will be an affiliated persons and related persons with respect to Lossco, Opco and each other. Lossco, Opco, ACo and Newco will be, during the implementation of the Proposed Transactions, related persons and affiliated persons. The structure will be dismantled before the contemplated maturity in the manner described in Paragraphs 21 to 29 if any entity previously mentioned in this Paragraph ceases to be affiliated following an acquisition of control by a non-affiliated third party.

35. Opco and Lossco are XXXXXXXXXX. ACo and Newco will be XXXXXXXXXX.

36. The Newco Preferred Shares will be term preferred shares.

37. The Newco Preferred Shares that will be acquired by ACo will not be acquired in the ordinary course of ACo's business.

38. The Newco Preferred Shares will not, at any time during the implementation of the Proposed Transactions described herein, be:

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

(b) the subject of a dividend rental arrangement;

(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), other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b)); or

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

39. Lossco is not a XXXXXXXXXX. ACo and Newco will not be XXXXXXXXXX.

40. The dividend paid on the Newco Preferred Shares to ACo, as described in Paragraph 22, has no other purpose than the purpose described in Paragraph 42.

40.1 Lossco and ACo will undertake steps to ensure that the interest income earned by Lossco under the Proposed Transactions will not materially exceed an amount that could be fully sheltered with Lossco’s non-capital losses. The interest deducted by ACo pursuant to paragraph 20(1)(c) in respect of Loan 2 will create a non-capital loss for ACo during the period in which the Proposed Transactions occur. The non-capital losses of ACo will be available for use to Opco after the wind-up described in Paragraph 28 subject to subsection 88(1.1). Opco expects to earn taxable income in excess of Lossco’s non-capital losses that will arise by virtue of the implementation of the Proposed Transactions. Any such non-capital loss will not be carried back to a prior taxation year and will be carried forward in a taxation year commencing after the commencement of the winding-up of ACo in accordance with the provisions of subsection 88(1.1) and section 111.

PURPOSES OF THE PROPOSED TRANSACTIONS

41. Absent the Proposed Transactions, it is expected that Lossco will annually generate non-capital losses. These non-capital losses are expected to accumulate in Lossco and would remain unused without implementation of the Proposed Transactions. The purpose of the Proposed Transactions is to effect a tax consolidation of Lossco and Opco in order to permit Opco to utilize the losses that Lossco is expected to incur in the XXXXXXXXXX taxation year and any non-capital losses of Lossco incurred in prior taxation years to the extent permitted by subsection 88(1.1) and 111. The purpose of the tax consolidation is not to shift income to a lower rate province. Any shift of income between provinces will be incidental to the Proposed Transactions.

42. The purpose of both the payment and the receipt of the dividends on the Newco Preferred shares as described in Paragraph 22 is to provide a reasonable return on such shares and to fund the interest payments made by ACo that will be due on Loan 2. More specifically, none of the purposes of the dividends is to reduce the fair market value or capital gain of any share, or to increase the total cost amounts of any properties.

43. Loan 2 is being made to ACo, instead of having Lossco make Loan 2 directly to Opco, to ensure that Opco, which is a public corporation, does not incur debt in order to implement the loss utilization.

44. The purpose of Parent obtaining the Parent Loan and lending that amount to Lossco under Loan 1, instead of Lossco borrowing amounts from an arm's length financial institution, is that Parent has lower borrowing costs than Lossco due to XXXXXXXXXX.

45. The purpose of incorporating Newco is to have Newco issue the Newco Preferred Shares to ACo, rather than having Lossco issue preferred shares directly to ACo which would result in corporate incest.

RULINGS

Provided that the preceding statements constitute a complete and accurate disclosure of all the relevant facts, proposed transactions, and purposes of the Proposed Transactions and provided further that the Proposed Transactions are carried out as described above, we rule as follows:

A. Subject to the application of subsection 69(11), provided the ACo Common Shares owned by Lossco are eligible property as defined in subsection 85(1.1), and provided the appropriate joint elections are filed in the prescribed form and manner within the time limit specified in subsection 85(6), the provisions of subsection 85(1), other than subsection 85(1)(e.2), will apply to the transfer of the shares of ACo from Lossco to Opco as described in Paragraph 25 such that the agreed amount in respect of the transfer of shares will be deemed to be Lossco’s proceeds of disposition and Opco’s cost of the particular eligible property, pursuant to paragraph 85(1)(a).

B. Provided that the requirements of paragraphs 88(1.1)(a) and (b) are satisfied, subsection 88(1.1) will apply to the winding-up of ACo into Opco described in Paragraph 28 such that, for the purposes of computing Opco’s taxable income under Part I or tax payable under Part IV for any taxation year commencing after the commencement of the winding-up, any remaining portion of the non-capital loss incurred by ACo will be deemed, for Opco’s taxation year in which ACo’s particular loss year ended, to be a non-capital loss of Opco derived from the source from which ACo derived the loss and that was not deductible by Opco in computing its taxable income for any taxation year that commenced before the commencement of the winding-up, subject to the limitations in paragraph 88(1.1)(e) and section 111. For this purpose, ACo will not be considered to have been wound up until it has been formally dissolved.

C. Provided that ACo has a legal obligation to pay interest on Loan 2 and ACo continues to hold the Newco Preferred Shares it acquires for the purpose of gaining or producing income from property, as described in Paragraph 16, ACo will, pursuant to paragraph 20(1)(c), be entitled to deduct, in computing its income for a taxation year (depending on the method regularly followed by ACo in computing its income for the purposes of the Act), the lesser of:

(a) the interest paid or payable on Loan 2 in respect of that taxation year; and

(b) a reasonable amount in respect thereof.

D. No amount will be included in the income of Newco pursuant to section 9, paragraphs 12(1)(c) or 12(1)(x) in respect of the contributions of capital to be made by Lossco as described in Paragraph 21.

E. Provided that the only purpose of the payment and receipt of the dividends on Newco’s Preferred Shares is as described in Paragraph 42, the provisions of subsection 55(2) will not apply to the dividends, if any, referred to in Ruling F, and received by ACo on the Newco Preferred shares.

F. The dividends received by ACo on its Newco Preferred Shares, as described in Paragraph 22, will be taxable dividends that will be deductible pursuant to subsection 112(1) in computing the taxable income of ACo for the taxation year in which the dividends are received, and for greater certainty, such deduction will not be precluded by any of subsections 112(2.1), 112(2.2), 112(2.3), or 112(2.4).

G. Neither Part IV.1 nor Part VI.1 will apply to the dividends described in Ruling E, as the dividends will be excepted dividends and excluded dividends.

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

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

J. The General Anti-avoidance Provision of an Agreeing Province will not be applied, as a result of the Proposed Transactions, in and by themselves, to redetermine the tax consequences confirmed in the rulings given above, in respect of a taxation year for which such Province was an Agreeing Province.

The above rulings are given subject to the general limitations and qualifications set out in Information Circular 70-6R12 dated April 1, 2022, and are binding on the CRA provided that the Proposed Transactions, as described in Paragraphs 10 to 20, are entered into on or before XXXXXXXXXX, and the Proposed Transactions related to the payment of interest and dividends and to the wind-up, as described in Paragraphs 21 to 29, are entered into on or before XXXXXXXXXX.

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) subject to Ruling J, the application or non-application of a general anti-avoidance provision of any province;

(f) the application of the proposed Excessive Interest and Financing Expenses Limitation rules originally released February 4, 2022 and revised November 3, 2022, or any amendments thereto, to the Proposed Transactions. and

(g) 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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