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Ruling
2005 Ruling 2004-0096311R3 - Deferred Share Units - Bonus Plan
If Annual Individual Goals and Annual Corporate Goals are only partially attained, the Participant may be entitled to receive a pro-rata portion of the Performance Vesting RSUs, the number of which will be determined at the discretion of the CEO or the Chair of the Board, as the case may be. e) No Participant shall be entitled to any benefit in respect of RSUs granted under the Plan to the extent that such RSUs have not vested in favour of the Participant. f) Subject to subparagraph 8(o) below, any RSUs applicable to a particular Grant to which a Participant does not become entitled under the Time Vesting Criteria, the Annual Corporate Goals or the Annual Individual Goals shall be forfeited immediately upon such determination. g) Upon the vesting of RSUs under the Plan, Pubco will determine the amount that is payable to a Participant based on the following formula: (Vested RSUs x Average Market Price on the Entitlement Date)- Tax Withholding = funds payable to the Participant h) The amount payable to the Participant (based upon the formula in subparagraph (g) above) will be paid to the Participant in cash. i) Pubco will pay amounts owing under the Plan to the Participant each year in which a Participant's RSUs vest. ...
Ruling
2012 Ruling 2012-0466731R3 - Donation of flow-through shares
There will be two forms of subscription agreement one for residents of XXXXXXXXXX under which the Resource Company will incur exploration expenses in XXXXXXXXXX, and one for residents of XXXXXXXXXX under which the Resource Company will incur exploration expenses in XXXXXXXXXX. ...
Ruling
2014 Ruling 2013-0510551R3 - Upstream Loans - Specified Debtor
Yours truly, XXXXXXXXXX Manager for Director International & Partnerships Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling
2013 Ruling 2012-0464841R3 - Distribution by a trust
Opco will reorganize its share capital and will file Articles of Amendment in order to: a) Delete the authorized but unissued non-voting preference shares in their entirety as well as all rights and restrictions attaching thereto; b) Create an unlimited number of Class A common shares, voting (as to XXXXXXXXXX votes per share), carrying the right to dividends declarable at the discretion of the Board of Directors; c) Create an unlimited number of Class B common shares, voting (as to XXXXXXXXXX votes per share), carrying the right to dividends declarable at the discretion of the Board of Directors; d) Create an unlimited number of Class D common shares, voting (as to XXXXXXXXXX votes per share), carrying the right to dividends declarable at the discretion of the Board of Directors; e) Create an unlimited number of Class W common shares, voting (as to XXXXXXXXXX votes per share), carrying the right to dividends declarable at the discretion of the Board of Directors; f) Create XXXXXXXXXX Class A preferred shares which shall be non-voting, carrying annual dividends in the aggregate amount of $XXXXXXXXXX, redeemable and retractable as described in Article XXXXXXXXXX, respectively, of the Articles of Amendment (the "Redemption Amount Class A"). ...
Ruling
2012 Ruling 2011-0426581R3 - Loss and XXXXXXXXXX tax consolidation
., document # XXXXXXXXXX) for this taxpayer except that the Proposed Transactions not only involve the utilization of Creditco's non-capital losses but also the XXXXXXXXXX tax credits of Creditco in respect of claims made in the XXXXXXXXXX to XXXXXXXXXX taxation years, and in the current and future taxation years. ...
Ruling
2012 Ruling 2011-0431051R3 - Charity's interest in a taxable corporation
With the exception of XXXXXXXXXX support, the XXXXXXXXXX program functions separately from the remaining operations of the Charity, including with respect to matters involving XXXXXXXXXX all of which are the responsibility of a committee of the XXXXXXXXXX, not the Charity's Board of Directors. 7. ...
Ruling
2014 Ruling 2013-0516071R3 - Reorganization
Unless otherwise stated, all statutory references herein are to the Act; "ACB" is the acronym for "adjusted cost base," which has the meaning assigned by section 54; "Amalco" has the meaning assigned in paragraph 26; "Amalco Preferred Shares" has the meaning assigned in paragraph 26; "Amalco Preferred Share Redemption Amount" has the meaning assigned in paragraph 26; "Amalco Redemption Note" has the meaning assigned in paragraph 28(c); "CRA" means Canada Revenue Agency; "dollars" or "$" means Canadian dollars; "EAI" is the acronym for "eligible alignment income" which has the meaning assigned in subsection 34.2(1); "Foreign Parent 1" means XXXXXXXXXX, a XXXXXXXXXX corporation; "Foreign Parent 2" means XXXXXXXXXX, a XXXXXXXXXX corporation; "GPco 1" means XXXXXXXXXX, an unlimited liability company governed by the XXXXXXXXXX; "GPco 2" means XXXXXXXXXX, an unlimited liability company governed by the XXXXXXXXXX; "Lossco" means XXXXXXXXXX, a corporation governed by the XXXXXXXXXX; "Lossco Preferred Shares" has the meaning assigned in paragraph 21; "Lossco Preferred Share Redemption Amount" has the meaning assigned in paragraph 21(b); "LP1" means XXXXXXXXXX, a partnership governed by the XXXXXXXXXX; "LP1 Units" mean the limited partnership units of LP1; "LP2" means XXXXXXXXXX, a partnership governed by the XXXXXXXXXX; "LP2 Units" means the limited partnership units of LP2; "multi-tier alignment election" has the meaning assigned by subsection 249.1(9); "Newco" has the meaning assigned in paragraph 23; "Profitco" means XXXXXXXXXX, a corporation governed by the XXXXXXXXXX; "Profitco Preferred Shares" has the meaning assigned in paragraph 22; "Profitco Preferred Share Redemption Amount" has the meaning assigned in paragraph 22(b); "Profitco Redemption Note" has the meaning assigned in paragraph 28(d); "QTI" is the acronym for "qualifying transitional income," which has the meaning assigned in subsection 34.2(1); "Subco" means XXXXXXXXXX, an unlimited liability company governed by the XXXXXXXXXX; and "taxable Canadian corporation" has the meaning assigned in subsection 89(1). ...
Ruling
2012 Ruling 2011-0427951R3 - Loss Consolidation
“Proposed Transactions” means the transactions described in 22 – 38 below; v. ...
Ruling
2014 Ruling 2014-0518521R3 - Issuance of a new class of units - Hedged Class
XXXXXXXXXX 2014-051852 XXXXXXXXXX, 2014 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX (the "Taxpayer") BN: XXXXXXXXXX This is in response to your letter dated XXXXXXXXXX wherein you requested an advance income tax ruling on behalf of the Taxpayer. ...
Ruling
2010 Ruling 2009-0341561R3 - Irish CCF
The Units will not have any voting rights (save the right, on written notice signed by Unitholders holding XXXXXXXXXX % of the Units, to require the Manager to resign). ...