Search - ”资源化利用" resources
Results 61 - 70 of 201 for ”资源化利用" resources
Public Transaction Summary
Progressive/Waste Management -- summary under Inversions
The shares of Progressive will then be consolidated (so that the Waste Connections shareholders have the same number of shares as before) – and Progressive will be renamed Waste Connections by means of amalgamation with a shell Ontario subsidiary with that name. ... Waste Connections A Delaware NYSE-listed integrated municipal solid waste services company that provides solid waste collection, transfer, disposal and recycling services primarily in exclusive and secondary markets in the U.S. and a leading provider of non-hazardous exploration and production waste treatment, recovery and disposal services in several of the most active natural resource producing areas of the U.S. ... U.S. tax considerations Code s. 7874 opinions The obligation to effect the Merger is conditional upon Progressive's and Waste Connections' receipt of Code s. 7874 opinions from Weil, Gotshal & Manges LLP and Locke Lord LLP, respectively, dated as of the closing date and subject to certain qualifications and limitations, to the effect that s. 7874 and the Treasury Regulations promulgated thereunder should not apply in such a manner so as to cause Progressive to be treated as a U.S. corporation for U.S. federal income tax purposes from and after the closing date of the Merger. ...
Public Transaction Summary
Bacanora -- summary under New Non-Resident Holdco
This exchange will occur on a taxable basis for Canadian purposes – and the AIM qualifies as a designated exchange for RRSP eligibility purposes. ... Its principal assets are the Sonora Lithium and Magdalena properties in Mexico held in direct or indirect Mexican subsidiaries (with Cadence, another resource company, as a minority shareholder). ... Any Bacanora Canada Shareholder who, either alone or together with persons connected with him, holds more than 5% of Bacanora Canada Shares is advised that clearance has been sought from HM Revenue & Customs under section 138 of the Taxation of Chargeable Gains Act 1992 in respect of the Arrangement. ...
Public Transaction Summary
Pan American/Tahoe -- summary under Shares for CVRs, and Shares or Cash
Pan American/Tahoe-- summary under Shares for CVRs, and Shares or Cash Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Mergers (mostly Plans of Arrangement)- Shares for CVRs, and Shares or Cash consideration for the proposed Pan American acquisition of Tahoe includes future contingent Pan American share deliveries Overview Under the proposed acquisition of Tahoe Resources by Pan American Silver pursuant to a B.C. ...
Public Transaction Summary
Filo/ BHP/ Lundin -- summary under Shares for Shares and Cash
Filo/ BHP/ Lundin-- summary under Shares for Shares and Cash Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Mergers (mostly Plans of Arrangement)- Shares for Shares and Cash Filo to be jointly acquired by BHP for BHP cash, and by Lundin Mining for cash and shares Overview It is proposed that Filo, a TSX-listed CBCA corporation indirectly holding a large deposit in Argentina and Chile, will be acquired by a Canadian joint venture company (JVCo) to be held on a 50-50 basis indirectly by (TSX-listed) Lundin Mining and by a Canadian subsidiary (BHP) in the BHP Group (the parent’s primary listing is in Australia). ... Josemaria Josemaria Resources Inc., the CBCA corporation through which Lundin Mining holds the Josemaria project in Argentina, which adjoins the Filo del Sol project of Filo. ...
Public Transaction Summary
Nuvo/Crescita -- summary under Butterfly spin-offs
Nuvo/Crescita-- summary under Butterfly spin-offs Summary Under Tax Topics- Public Transactions- Spin-Offs & Distributions- Butterfly spin-offs Nuvo Research butterfly spin-off of Crescita Overview. ... Will be a drug development company with a diversified pipeline of product candidates and sufficient cash resources to execute its current business plan for the next 24 months. ...
Public Transaction Summary
GWRC/GWRI -- summary under Outbound mergers
Plan of Arrangement), with GWRI as the survivor – following which a public offering by GWRI would be completed. ... GWRI operates in the Western U.S. as a water resource management company that owns and operates regulated water, wastewater and recycled water utilities, principally in metropolitan Phoenix, Arizona. ...
Article Summary
Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114 -- summary under Subsection 90(1)
Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114-- summary under Subsection 90(1) Summary Under Tax Topics- Income Tax Act- Section 90- Subsection 90(1) Most pro rata corporate distributions are dividends (pp. 20:16-17) Cangro Resources … held that for the purposes of the Act, “dividend” was to be given its “accepted ordinary meaning” – that is, of a pro rata distribution to all shareholders, other than a formal reduction of paid-up capital or liquidating distribution. … Despite the CRA’s administrative practice, the essence of a dividend, according to the jurisprudence, is a pro rata distribution by a corporation among its shareholders that is not a reduction of capital or a liquidating distribution. ...
TCC (summary)
212535 Oil & Gas Ltd. v. MNR, 96 DTC 1263, [1996] 1 CTC 2416 (TCC) -- summary under Res Judicata
212535 Oil & Gas Ltd. v. MNR, 96 DTC 1263, [1996] 1 CTC 2416 (TCC)-- summary under Res Judicata Summary Under Tax Topics- General Concepts- Res Judicata Rip TCJ. found (at p. 1266) that "where the parties to the litigation are different there is no res judicata, even when the facts are identical". Accordingly, the taxpayers, who were members of a group that had purchased interests in a resource property were not precluded from raising the same arguments that had been previously rejected by the Tax Court and the Federal Court of Appeal in an appeal by another member of the same purchasing group. ...
TCC (summary)
Northwest Hydraulic Consultants Ltd. v. R., 98 DTC 1839, [1998] 3 CTC 2520 (TCC) -- summary under Scientific Research & Experimental Development
., 98 DTC 1839, [1998] 3 CTC 2520 (TCC)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development 5 factors test The taxpayer was an engineering consultant firm that specialized in the development, management and protection of water resources. ...
TCC (summary)
212535 Oil & Gas Ltd. v. MNR, 96 DTC 1263, [1996] 1 CTC 2416 (TCC) -- summary under Eligible Capital Expenditure
212535 Oil & Gas Ltd. v. MNR, 96 DTC 1263, [1996] 1 CTC 2416 (TCC)-- summary under Eligible Capital Expenditure Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Eligible Capital Expenditure Each taxpayer closed the purchase of a 10% interest in a resource property by giving the vendor an interest-bearing demand promissory note for $3.5 million. ...