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Ruling

2002 Ruling 2002-0118963 - PHANTOM STOCK PLAN

In general, this means that XXXXXXXXXX % of an Eligible Director's retainer fees for a year and meeting fees for meetings held within a Quarter in that year become payable at the end of the Quarter. ...
Ruling

2002 Ruling 2002-0123203 - DEFERRED SHARE/UNIT PLAN DIRECTORS

If the Eligible Director elects to participate in the Plan, he or she may choose to receive: (i) XXXXXXXXXX%, (ii) XXXXXXXXXX %, (iii) XXXXXXXXXX% or (iv) XXXXXXXXXX% of his or her Directors' Annual Remuneration in DSUs under the Plan, with the remainder (if any) of such Directors' Annual Remuneration to be paid in cash, net of the applicable withholding taxes, to the Eligible Director. ...
Ruling

2002 Ruling 2002-0127013 - Estate Planning

The capital gain on the deemed disposition of XXXXXXXXXX shares at the time of death was $ XXXXXXXXXX and the adjusted cost base of the XXXXXXXXXX Holdings Class A shares to the Estate is $XXXXXXXXXX. ...
Ruling

2002 Ruling 2002-0132913 - SAME BUSINESS

The partners of Partnership A and their interests in Partnership A are Company A (XXXXXXXXXX %), Company B (XXXXXXXXXX%) and Company C (XXXXXXXXXX%) and Company A1 (XXXXXXXXXX%). ...
Ruling

2002 Ruling 2002-0163383 - Derivatives - Foreign property rules

Reasons: Similar to ruling # E 2001-0079143 and E 2002-016141 XXXXXXXXXX 2002-016338 XXXXXXXXXX, 2002 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request XXXXXXXXXX This in reply to your letter of XXXXXXXXXX, in which you requested an advance income tax ruling in respect of the income tax consequences arising from the proposed transactions described below. ...
Ruling

2002 Ruling 2002-0168463 - REIT with seconded employees

Definitions In this letter, unless otherwise indicated, all statute references are to the Income Tax Act and Regulations, R.S.C. 1985 (5th supp.) c. 1, as amended (the "Act"), and the following terms have the meaning specified: "Amalco" means the corporation that will result from the amalgamation of XXXXXXXXXX Following the amalgamation, XXXXXXXXXX% of the voting shares will be owned indirectly by XXXXXXXXXX and persons related to him and XXXXXXXXXX % of the voting shares will be owned indirectly by XXXXXXXXXX and persons related to him. ...
Ruling

2003 Ruling 2001-011123A - Foreign affiliate reorg; Deemed Active Income

Yours truly, XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch ...
Ruling

2017 Ruling 2015-0605161R3 - Fonds commun de placement (FCP) - Luxembourg

XXXXXXXXXX 2015-060516 XXXXXXXXXX, 2017 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX We are writing in reply to your letter of XXXXXXXXXX, with a subsequent revision on XXXXXXXXXX, in which you requested an advance income tax ruling on behalf of the above-referenced persons. ...
Ruling

1999 Ruling 991426A - RETURN OF PUC BY PUBLIC CORPORATION

The aggregate adjusted cost base of the common shares of A Co. owned by C Co. is, approximately, $ XXXXXXXXXX. ...
Ruling

1999 Ruling 9918653 - BUTTERFLY REOGANIZATION

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayers or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ...

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