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Ruling

2010 Ruling 2010-0353901R3 - Common Contractual Funds

The Sub-Fund1 Units and the Sub-Fund2 Units will not have any voting rights except the right, on written notice signed by Unitholders holding XXXXXXXXXX % of the units of Sub-Fund1 and Sub-Fund2, to require the Manager to resign. ... Yours truly, for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling

2009 Ruling 2007-0220151R3 - funded pension plan

For the purposes of the Plan, the Company shall convert Earnings received in a currency other than the lawful currency of Canada into the lawful currency of Canada using an appropriate methodology selected by the Company and used consistently from year to year; (i) "Effective Date" means: the date as of which the Initial Letter of Credit is to be issued; (j) "Employee" means: a person who is employed by an Employer; (k) "Employer" means: the Company or a company that is affiliated or associated with the Company that is designated by the President or any XXXXXXXXXX Directors of the Company, as an Employer, provided such company adopts the Plan and agrees to make the Notional Employer Contributions required under the Plan in respect of its Employees; (l) "Event of Default" means: an occurrence of an event, as specified in the Trust Agreement, which requires the Trustee to demand payment under a letter of credit; (m) "Initial Letter of Credit" means: a Letter of Credit as described in 29 below; (n) "Investment Options" means: the notional investment options described in 10 below; (o) "Notional Account" means: an account described in 7 below; (p) "Notional Employer Contributions" means: notional contributions as described in 7, 8 and 23 below, as applicable, that are made to a Plan Member's Notional Account by the Plan Member's Employer; (q) "Notional Investment Earnings" means: the notional amount of investment income credited to a Plan Member's Notional Account pursuant to the provisions described in 7 below; (r) "Plan" means: before the proposed transactions, the "XXXXXXXXXX ", sponsored and maintained by the Company, as described in 3 through 18 below, and after the proposed transactions, the "XXXXXXXXXX " as described in 3 through 18 and 19 through 27 below; (s) "Plan Member" means a DC Member or a TCN Member, as applicable. ...
Ruling

2010 Ruling 2010-0354081R3 - Partnership Reorg-Personal Services Business

The distribution is determined annually by approval of not less than XXXXXXXXXX % of the Partners. ... (e) Upon the death of a Partner, the deceased Partner's partnership interest is forfeited and the deceased Partner's estate is entitled to XXXXXXXXXX % of the Partner's Tax-Paid Capital and any distributable but unpaid profits allocated to the deceased Partner in respect of the portion of the current or prior fiscal periods preceding death. ...
Ruling

2009 Ruling 2009-0337651R3 - Reverse Earnout - Application of 12(1)(g)

Negotiations are ongoing and while a final draft of the purchase and sale agreement is not currently available, it is anticipated that the final form of the purchase and sale agreement for the Target Shares, which will be governed by the law of XXXXXXXXXX, will include the key terms as described in paragraphs 3.2 to 3.10 below. 3.2 The Vendor and the Purchaser will agree that at Closing, the Target will not hold the Excluded Assets, nor will it be responsible for the Excluded Liabilities. 3.3 The Purchase Price will be equal to approximately XXXXXXXXXX and will consist of the following components: (a) XXXXXXXXXX payable in cash at Closing; (b) an amount equal to the amount of the Surplus Assets, payable at or immediately following Closing in cash, cash equivalents or a combination thereof (in Purchaser's sole discretion); (c) XXXXXXXXXX payable in cash no later than the XXXXXXXXXX anniversary following the Closing, and (d) XXXXXXXXXX (which is anticipated to constitute a significant percentage of the Purchase Price) payable without interest in cash, in quarterly amounts, commencing for the quarter ended XXXXXXXXXX and for each full quarter thereafter, payable no later than XXXXXXXXXX days following the last date of each quarter, with each such payment to be in an amount that is equal to XXXXXXXXXX % of the Quarterly Additional Product Consideration for such quarter. 3.4 Notwithstanding the payment terms set forth in paragraph 3.3(d) above, upon at least XXXXXXXXXX business days' written notice to the Vendor, at any time or from time to time, as applicable, the Purchaser or an affiliate thereof may pay the Vendor any or all of the balance of the Obligation not previously paid to the Vendor based on the Quarterly Additional Product Consideration pursuant to paragraph 3.3(d). ... In other words, the Purchase Price will be reduced by the unpaid amount of the Obligation if the cumulative amount of the Quarterly Additional Product Consideration received by the Target and/or any successor or permitted assignee thereof (XXXXXXXXXX % of which is paid or payable to the Vendor under paragraph 3.3(d) above) during the period ending on the Threshold Anniversary is less than the Threshold Amount. ...
Ruling

2009 Ruling 2008-0302121R3 - Partnership Reorg-Personal Services Business

Other decisions with respect to the following matters require the approval of XXXXXXXXXX % of the Partners present: (i) any amendment to the Partnership Agreement; (ii) any amendment to the Income Distribution Plan; (iii) the admission of a new Partner; and (iv) the expulsion of a Partner. ... (e) A quorum of XXXXXXXXXX % of all Partners is required at a duly constituted business meeting with respect to any decisions of the Partners. ...
Ruling

2007 Ruling 2007-0244691R3 - reorg of an existing REIT to eliminate subtrust

Provided that: a) each of Trust B and the Fund is a mutual fund trust within the meaning of subsection 132(6) at the Transfer Time; b) the property transferred by Trust B to the Fund has an aggregate fair market value equal to at least XXXXXXXXXX % of the fair market value of all property owned by Trust B at the Transfer Time; and c) Trust B and the Fund jointly elect, in prescribed form within the prescribed time in paragraph (c) of the definition of "qualifying exchange" in subsection 132.2(2), the transactions described in paragraphs 32 to 36 will constitute a "qualifying exchange" such that the rules in subsection 132.2(1) will apply to such transactions. ... XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling

2006 Ruling 2005-0160571R3 - Transfer of asset to a REIT by a tax-exempt entity

Any investor or group of investors that holds at least XXXXXXXXXX % of the units of the REIT will be entitled to appoint a member to the Board of Trustees of the REIT. ... Yours truly, XXXXXXXXXX Section Manager For Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling

2006 Ruling 2005-0143361R3 - split assets of 3 trusts into 5 separate trusts

& B Yes C&D. No Reasons: A.. Substantially the same issues as in past ruling 2002-018047. ... XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling

2007 Ruling 2006-0201561R3 - settlement of an estate

Pursuant to the Minutes of Settlement, the Parties will apply to the Court to have the Will and the Trusts created under the Will varied in the following manner: (a) Codicil A and its subsequent revocation will be ignored; andXXXXXXXXXX; (b) the Estate will be administered as if the residue clause in paragraph XXXXXXXXXX of the Will remained in effect as originally set out in the Will, subject to the variation set out below: (i) with respect to the residue of the Estate described in paragraph XXXXXXXXXX of the Will, the Children will be entitled to XXXXXXXXXX% of the residue such that each Child receives one-third of that amount, and XXXXXXXXXX % of the residue will be settled on the Trusts such that Trust1, Trust2 and Trust3 each receive one-third of that amount; (ii.1) the Children will not be entitled to any of the income or capital of any of Trust1, Trust2 or Trust3; (ii) references to the vesting of a Grandchild's share of the Estate described in paragraph 5(a) and (c) above will be changed from age XXXXXXXXXX to age XXXXXXXXXX; (iii) subparagraph XXXXXXXXXX of the Will will be amended to provide that payments of income and capital for the benefit of a Grandchild will continue to be discretionary beyond age XXXXXXXXXX until the capital is distributed at age XXXXXXXXXX and that the Trustees are directed to take into account any other resources which the Trustees reasonably believe are, or should be, available to such Grandchild, including the means of his or her parents or guardians when considering making distributions to a Grandchild; and (iv) the provision governing distribution of a Grandchild's share if he or she dies before the age of XXXXXXXXXX will be changed to delete members of his or her parent's generation as potential recipients of that Grandchild's share in the event that the Grandchild dies without issue before the final distribution from the Trust. 14. ... XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling

2004 Ruling 2004-0098931R3 - Subsections 7(1.4) and 7(1.5) Exchanges

(j) "DC Common Shares " means the voting common shares of DC described in 2 below. ... Yours truly, Director Financial Industries Division Income Tax Rulings Directorate Policy & Planning Branch ...

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