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Ruling
2008 Ruling 2008-0269991R3 - Partner creating contracting company
(b) Each calendar month, a Partner is entitled to a "Monthly Income Allocation" based on XXXXXXXXXX % of all funds received in that month to the account of fees billed and collected by that Partner. ...
Ruling
2007 Ruling 2006-0216551R3 - Interest Expense - Substituted Property
The consideration provided by Finance Co was common shares of Finance Co with a fair market value equal to the fair market value of XXXXXXXXXX % of the B Co Shares. ...
Ruling
2007 Ruling 2006-0201321R3 - Borrowed money, shares of subsidiary
Interest payable on XXXXXXXXXX Certificates of Deposit is XXXXXXXXXX% per annum each and one Certificate of Deposit carries an interest rate of XXXXXXXXXX %. ...
Ruling
2007 Ruling 2007-0260861R3 - Entity Classification
Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling
2007 Ruling 2007-0242361R3 - Donation of flow-through shares
This holding will represent less than XXXXXXXXXX % of the outstanding shares of the Resource Company. ...
Ruling
2007 Ruling 2007-0252491R3 - Assumption of debt for assets
The notes bear interest at the rate of XXXXXXXXXX % per annum and mature on XXXXXXXXXX. ...
Ruling
2006 Ruling 2005-0149101R3 - Amending trust indenture and subdividing units
Yours truly, XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling
2006 Ruling 2004-0091961R3 - XXXXXXXXXX Indian reserve loan insurance arrangement
Yours truly, XXXXXXXXXX Section Manager For Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling
2006 Ruling 2006-0189151R3 - Reasonableness Shareholder Manager Remuneration
. / Tax Services Social Insurance No. Office XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX The Tax Services Office for each Taxpayer is shown above. ...
Ruling
2006 Ruling 2006-0184571R3 - Loss utilization in related companies
By directors' resolution Holdco will authorize the issuance of a new series of preferred shares (the "Holdco Preferred Shares") with the rights and restrictions as follows: (a) non-voting; (b) annual cumulative dividend rate equal to the Opco Subordinated Rate + XXXXXXXXXX%; (c) redeemable for an amount equal to the aggregate of the amount for which the shares were issued and any unpaid dividends; (d) retractable for an amount equal to the aggregate of the amount for which the shares were issued and any unpaid dividends; (e) dividends and proceeds on winding up or dissolution rank ahead of any payment on shares ranking junior; (f) on winding up or dissolution, holders will receive an amount equal to the aggregate of the amount for which the shares were issued and any unpaid dividends; and (g) will be automatically retracted three days prior to any bankruptcy or insolvency of Holdco. 10. ...