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Ruling

2022 Ruling 2020-0873371R3 - Multi-wing split-up net asset butterfly

Holdco 2 is controlled by Siblingco 2 and Siblingco 3, which are each controlled by Sibling 2 and the Sibling 3 XXXXXXXXXX Trust, respectively. ... On XXXXXXXXXX, a vertical short-form amalgamation of Subco 2 and its wholly-owned subsidiary, Subco 2 Sub, was completed. ... The members of Consolidated Group 2 will transfer their shares in the capital stock of each of Canco 1, Canco 2, Canco 3, Canco 4, Canco 5, Canco 6, Canco 7, Canco 8, Canco 9 and Canco 10 to Newco 2 in exchange for the issuance of the common shares of the capital stock of Newco 2. ...
Ruling

2019 Ruling 2018-0788191R3 F - Butterfly Transaction

Faits relatifs à Opco 2 24. Opco 2 a été constituée en vertu de XXXXXXXXXX, et est toujours régie par XXXXXXXXXX. Opco 2 est une SCI et une SPCC. L’Année d’imposition d’Opco 2 prend fin le XXXXXXXXXX de chaque année. 25. ... Cédante recevra à titre de contrepartie pour les biens transférés à Opco 2: a) la prise en charge par Opco 2, d’une partie des dettes de Cédante; b) des actions de catégorie « E » du capital-actions d’Opco 2. ...
Ruling

2017 Ruling 2017-0699201R3 - Cross-border Butterfly

Foreign Subco 2 is a Non-Resident corporation, which was established under the laws of Country 2 in XXXXXXXXXX. ... The Newco Common Shares will be Eligible Property at the time of the DC Transfer 2. 43. ... DC’s earnings have routinely been distributed to Foreign Subco 2 as dividends. ...
Ruling

2019 Ruling 2018-0758411R3 - Multi-wing split-up net asset butterfly

Legal Titleholder 2 13. Legal Titleholder 2 is a CCPC and a taxable Canadian corporation, which was incorporated XXXXXXXXXX under the BCA. 14. ... Legal Titleholder 2 has had no activity since its incorporation. Legal Titleholder 2 earns no revenue and its assets are of nominal value. 16. ... A and 2 unrelated trustees; (c) The beneficiaries of the Trust A2 are the issue of Mr. ...
Ruling

2015 Ruling 2014-0532201R3 - Corporate reorganization

Trust 4’s transfer of shares in Corporation 2 and Corporation 3 to Holdco 2 27. ... The aggregate amount added to the Stated Capital of the common shares in Holdco 2 will not exceed the aggregate cost to Holdco 2 of the shares in Corporation 2 and Corporation 3 less the amount of liabilities, if any, to be assumed by Holdco 2. ... Day 2 Newco’s incorporation 49. Corporation 25, Trust 2 and Corporation 19 will incorporate Newco under the XXXXXXXXXX. ...
Ruling

2001 Ruling 2001-0086553 - PARTNERSHIP; AT-RISK

Under the arrangements with Canco #2, Canco #3 XXXXXXXXXX. Commercial Environment 5. ... Canco #2 will enter into an agreement with Canco #3 whereby Canco #2 will agree to pay $XXXXXXXXXX of the indebtedness of Canco #3 that is XXXXXXXXXX. ... Lender #1 will prepay interest to Canco #2 on the Canco #2/Lender #1 Loan in the amount of $XXXXXXXXXX, which will be included in the income of Canco #2. ...
Ruling

2021 Ruling 2019-0827591R3 - Split-up butterfly

No shares have been issued by TC 2, and no activities have been carried out by TC 2 since its incorporation. ... DC and TC 2 30. TC 2 will redeem all of the TC 2 Class F Preference Shares owned by DC (the TC 2 Redemption) for an amount equal to the aggregate TC 2 Class F Redemption Amount. ... TC 2 will not designate the TC 2 Dividend to be an Eligible Dividend under subsection 89(14). 32. ...
Ruling

2019 Ruling 2018-0761621R3 - Cross-Border Butterfly

Forco 2 9. Forco 2 is a Non-Resident corporation. All of the issued and outstanding common shares of Forco 2 are owned by Foreign Pubco. ... CanSpinco 2 is a TCC and a PC. All of the issued and outstanding common shares of CanSpinco 2 are owned by CanSpinco 1. ... With respect to the Cash Sweeping 2, CanSpinco 1 is the cash pool head entity and the Cash Sweeping 2 participants are CanSpinco 1, CanSpinco 2 and CanSpinco 3. ...
Ruling

2017 Ruling 2016-0679281R3 - subsections 84(4.1) and 86(1)

Parent is a Public Corporation and a Taxable Canadian Corporation, which is governed by Act 2. ... Canadian Subsidiary is a Taxable Canadian Corporation, which is governed by Act 2. ... Specified Subsidiary 1 and Specified Subsidiary 2 16. Specified Subsidiary 1 and Specified Subsidiary 2 each are limited liability companies formed under the laws of XXXXXXXXXX. ...
Ruling

2005 Ruling 2005-0113301R3 - Butterfly

DC was incorporated on XXXXXXXXXX and is governed by the provisions of the CBCA. 2. ... Transfer of Trust2's shares to Transferee 2 32. Trust2 will transfer a portion of its XXXXXXXXXX Common shares of DC to Transferee 2 at fair market value. ... DC will accept the promissory note issued by SubCo 2 (the "SubCo 2 Note") as full payment for the Redemption Price of the Class A preferred shares of SubCo 2. ...

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