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Technical Interpretation - External
16 October 1990 External T.I. 9014515 F - Resource Industries - Prescribed Share Excluded from Meaning of Flow-through Share
16 October 1990 External T.I. 9014515 F- Resource Industries- Prescribed Share Excluded from Meaning of Flow-through Share Unedited CRA Tags 66(15) flow-through share, 66(15) selling instrument, 66(15) principal-business corporation, ITR 6202.1(1), 6202.1(5) 24(1) Resource Industries Section Allan Nelson (613) 957-8984 5-901451 19(1) October 16, 1990 Dear Sirs: Re: Paragraph 6202.1(1)(d) of the Regulations to The Income Tax Act We are writing in response to your letter of June 20, 1990, wherein you requested our views concerning the application of paragraph 6202.1(1)(d) of the Regulations to the Income Tax Act ("Regulation 6202.1(1)(d)"). ... Drillco say also joint venture with Oilco. 4. The selling instrument indicates as follows: (a) that investment in the shares is highly speculative; (b) that no market exists for the shares and that it may be difficult or even impossible for a subscriber to sell his securities. ... Yours truly, ChiefResource Industries SectionBilingual Services & Resource Industries Division ...
Technical Interpretation - Internal
19 November 1990 Internal T.I. 9030467 F - Hedging Gains Resource Allowance
19 November 1990 Internal T.I. 9030467 F- Hedging Gains Resource Allowance Unedited CRA Tags n/a November 19, 1990 E.H. ... Shaw 957-8968 Attention: S. Lakhani 7-903046 SUBJECT: Hedging gains Resource Allowance This is in reply to your memorandum of October 29, 1990 in which you requested our confirmation that Brian Dawe's July 8, 1983 memorandum setting out an "administrative position" that hedging gains and losses would be taken into account in computing resource profits for the purposes of the resource allowance deduction where the hedge is satisfied by a delivery of the hedger's production was, and remains, in accordance with our views of the law. ... HMQ 84 DTC 6535- Gunnar Mining Limited v. MNR 68 DTC 5035- Guthrie v. ...
Public Transaction Summary
Chalice/Coventry -- summary under Asset sale/share distribution
Chalice/Coventry-- summary under Asset sale/share distribution Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Cross-Border Acquisitions- Inbound- Asset sale/share distribution Chalice Gold acquisition of Coventry Resources assets for shares, followed by share distribution Overview Under a BC Plan of Arrangement, Coventry is to transfer most of its subsidiaries (the "Targets") to Western Rift (a subsidiary of Chalice) in consideration for Chalice shares, which Coventry will then transfer to its shareholders as a stated capital distribution. ...
Public Transaction Summary
Serabi/Kenai -- summary under Canadian Buyco
Serabi/Kenai-- summary under Canadian Buyco Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Cross-Border Acquisitions- Inbound- Canadian Buyco Serabi plc acquisition of Kenai Resources Overview Under a B.C. plan of arrangement, shareholders of Kenai will receive ordinary shares (and no deferred shares) of Serabi (representing an 87% premium). ... Plan of Arrangement Under the Plan of Arrangement: Each common share of a dissenter will be transferred for its fair value to Subco Each common share of Kenai, other than of a dissenter, will be transferred to Subco in consideration for the right to cause the delivery of.85 of an ordinary Serabi share As consideration for the issuance of each such ordinary Serabi share, Subco will issue one Subco share and add its fair market value to its stated capital account The Kenai warrants will be amended so that they apply to Serabi shares, with the exercise price and number of covered shares adjusted accordingly Each Kenai stock option will be exchanged for a replacement option on a Serabi share, with a view to s. 7(1.4) applying Subco and Kenai will amalgamate under the name Kenai Resources Ltd., with each Subco share continuing as an Amalco share, and with the stated capital of the shares of Amalco being the stated capital of the Subco shares issued under the arrangement plus the amount of cash to fund payments to dissenters U.S. ...
TCC
Bennett v. Human Resources, docket 2000-1978-OAS
Human Resources, docket 2000-1978-OAS Date: 20010904 Docket: 2000-1978-OAS BETWEEN: IVOR A. BENNETT, Appellant, and THE MINISTER OF HUMAN RESOURCES AND DEVELOPMENT CANADA, Respondent. ... BENNETT, Appellant, and THE MINISTER OF HUMAN RESOURCES AND DEVELOPMENT CANADA, Respondent. ...
Technical Interpretation - Internal
15 November 1990 Internal T.I. 9030887 F - Resource Allowance
15 November 1990 Internal T.I. 9030887 F- Resource Allowance Unedited CRA Tags 1210(a)(i)(B) November 15, 1990 Mr. ... D'Aurelio Resource Industries Director Section Current Amendments and J. ... Burnett your file NQF-3377 our file 7-903088 SUBJECT: Clause 1210(a)(i)(B) of the Income Tax Regulations In reply to your memorandum of October 29, 1990, we intend to support Finance's position on the issue relating to the above identified in our memorandum of October 30, 1989 to you. ...
Public Transaction Summary
Whitecap/ Veren -- summary under Share-for-Share
Whitecap/ Veren-- summary under Share-for-Share Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Mergers (mostly Plans of Arrangement)- Share-for-Share Whitecap Resources acquire all the shares of Veren on a s. 85.1 exchange Overview It is proposed that under a Plan of Arrangement under the Business Corporations Act (Alberta), all of the outstanding shares of Veren will be exchanged, generally on a s. 85.1 rollover basis, for shares of Whitecap on the basis of 1.05 Whitecap shares for each Veren share. ...
TCC
Bouchard v. Human Resources, 2008 TCC 408
Human Resources, 2008 TCC 408 Docket: 2008-387(OAS) BETWEEN: ANDRÉ BOUCHARD, Appellant, and THE MINISTER OF HUMAN RESOURCES AND SOCIAL DEVELOPMENT, Respondent. ... Translation certified true this 22nd day of September 2008 Stefan Winfield, Reviser Citation: 2008TCC408 Date: 20080707 Docket: 2008-387(OAS) BETWEEN: ANDRÉ BOUCHARD, Appellant, and THE MINISTER OF HUMAN RESOURCES AND SOCIAL DEVELOPMENT, Respondent. ... [2] The issue is whether the Minister of Human Resources and Social Development (the Minister) properly took account of a QPP disability pension amount of $12,401.16 that the Appellant received from the Régie des rentes du Québec during the 2006 taxation year ...
TCC
Brighton v. Canada (Human Resources ans Skills Developement), 2013 TCC 323
Canada (Human Resources ans Skills Developement), 2013 TCC 323 Docket: 2013-1442(OAS) BETWEEN: GAIL BRIGHTON, Appellant, and THE MINISTER OF HUMAN RESOURCES AND SKILLS DEVELOPMENT, Respondent. ____________________________________________________________________ Appeal heard on July 18, 2013, at Nanaimo, British Columbia Before: The Honourable Justice B. ... Citation: 2013TCC323 Date: 20131015 Docket: 2013-1442(OAS) BETWEEN: GAIL BRIGHTON, Appellant, and THE MINISTER OF HUMAN RESOURCES AND SKILLS DEVELOPMENT, Respondent. REASONS FOR JUDGMENT Paris J. [1] Ms. Brighton has appealed the decision of the Minister of Human Resources and Skills Development (“the Minister”) that she was not entitled to any amount of the Guaranteed Income Supplement (GIS) under the Old Age Security Act (OAS) for the period from July 1, 2012 to June 30, 2013 ...
TCC
Parrotta v. Human Resources, 2012 TCC 172
Human Resources, 2012 TCC 172 Docket: 2011-2012(OAS) BETWEEN: RACHELE PARROTTA, Appellant, and THE MINISTER OF HUMAN RESOURCES AND SKILLS DEVELOPMENT, Respondent.____________________________________________________________________ Appeal heard on common evidence with the appeal of Domenico Parrotta (2011-2007(OAS)) on March 21, 2012, at Toronto, Ontario Before: The Honourable Justice B. ... Docket: 2011-2007(OAS) BETWEEN: DOMENICO PARROTTA, Appellant, and THE MINISTER OF HUMAN RESOURCES AND SKILLS DEVELOPMENT, Respondent.____________________________________________________________________ Appeal heard on common evidence with the appeal of Rachele Parrotta (2011-2012(OAS)) on March 21, 2012, at Toronto, Ontario Before: The Honourable Justice B. ... Citation: 2012TCC172 Date: 20120518 Dockets: 2011-2012(OAS) 2011-2007(OAS) BETWEEN: RACHELE PARROTTA, DOMENICO PARROTTA, Appellants, and THE MINISTER OF HUMAN RESOURCES AND SKILLS DEVELOPMENT, Respondent. ...