Search - 侵犯公民个人信息罪 交易明细 计算条数

X of the preferred shares would be attributable to the capital gains deduction – so that there would be a deemed dividend of $500,000 paid by Cco to Mr. ...

Proposed transactions Employerco will amend the terms of the Company Group RRSP to provide that an Employee or Executive Employee can elect that up to 8%, of the their base salary plus any STIP Bonus received in a pay period, will be deducted from such pay and contributed to the Company Group RRSP, and that Employerco will make a contribution to the Company Group RRSP of the lesser of 125% of such employee contribution during the year; and 5/9th of the RRSP dollar limit under the Act for that year, or such lower amount as may be specified by the employee – with the employee responsible for ensuring that the total of such contributions does not exceed the applicable RRSP contribution limits. ...

All the Class D shares of Zco held by Trust 2 were exchanged under s. 51 for Class D non-voting and participating shares, Class E non-voting preferred shares and Class F preferred shares (bearing a dividend that was potentially discretionary) – and then made a further s. 51 exchange of Class D for Class D and E shares. ...

X, CRA indicated that Amalco shares that were substituted for his Holdco common shares had not been held by anyone other than him, and that, prior to being replaced by Holdco shares, the original Opco share had not been owned by anyone other than him – and in this regard, stated that s. “110.6(1)(e) can apply respecting multiple substitutions.” ...

. … In order to be eligible for a joint designation, amounts must be distributed from the FHSA to the estate before the deceased holder's FHSA ceases to be a FHSA, generally before the end of the year following the year of the holder's death, unless the FHSA ceased to be a FHSA at an earlier date under subsection 146.6(16). ...

Pubco (acting through a branch in Country 1 – assumed here to be Luxembourg) will subscribe with cash for common shares and/or mandatorily redeemable preferred shares ("MRPS") of Finco. ...

In determining the net FMV of each type of property of DC and its subsidiaries (anticipated to be cash or near-cash property and business property), (a) the net FMV of any accounts receivable, trade receivables, inventories and prepaid expenses of such corporation or partnership remaining after the allocation of current liabilities to cash or near-cash property will be reclassified as business property "to the extent that such property will be collected, sold, used or consumed in the ordinary course of business to which such property relates," and (b) any current ("as determined by the method prescribed by the applicable pension legislation") pension plan, post-retirement benefit or liability insurance liabilities of DC will be allocated to cash or near-cash property, and any such liabilities of a non-current nature will be allocated to business property – and similarly for employee incentive plans. ...

Proposed transactions The following transactions will occur under a Plan of Arrangement to accomplish a spin-off of Subco 1 and 2 Transferred Business through Spinco, which was incorporated but has no shareholders: Under a s. 86 reorganization, each DC shareholder will exchange all of its DC common shares for "DC Butterfly Shares" and Class D, E or F common shares (with the aggregate paid-up capital of the exchanged shares being apportioned), such that the aggregate fair market value of the DC Butterfly Shares will be equal to the "Butterfly Ratio" (equal to the relative net FMV of Subco 1 Transferred Business 1 and 2) multiplied by the aggregate FMV of all the DC shares held immediately before the exchange – and the FMV of the Class D, E or F common shares received on the exchange will capture the balance of the FMV of the exchanged Class A, B or C common shares. ...

. … These corporate documents are not bilateral contracts…. Shares may or may not carry votes, but in respect of the governance of the corporation, typically only shareholders may vote on matters such as the election of the board of directors. ...

Rulings The s. 55(3)(a) exception will apply to the dividends in 1, 3 and 7, provided there is not a disposition of property or an increase in interest described in ss. 55(3)(a)(i) to (v) which is part of the series of transactions or events – and the proposed transactions, by themselves, will not be considered to result in any disposition to, or increase in interest by, an unrelated person described in ss. 55(3)(a)(i) to (v). ...