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Ruling
30 November 1997 Ruling 9805113 - BUTTERFLY REORGANIZATION
On the incorporation of XXXXXXXXXX, 1 common share will be issued to XXXXXXXXXX for aggregate consideration of $ XXXXXXXXXX. 20. ...
Ruling
30 November 1997 Ruling 9818683 - 21-YEAR DEEMED DISPOSITION RULE
Position TAKEN: 1) No 2) No 3) Yes 4) No Reasons FOR POSITION TAKEN: 1) Consistent with the position in IT-385R2 and in previous rulings (973094, 972779 & 970604) 2) The variation is not significant enough to consider that there has been a disposition (972779). 3) The Distribution pursuant to subsection 107(2) is consistent with Finance's comments contained in the Technical Notes regarding the 21-year rule. 4) This issue was referred to the GAAR Committee and it was recommended that GAAR not apply to the proposed transactions. ...
Ruling
2003 Ruling 2002-0174053 - Internal Reorganization
(b) Canco1 and the Lessee entered into a purchase and sale agreement ("Purchase and Sale Agreement ") which provided, inter alia, that Canco1 would sell the XXXXXXXXXX to the Lessee for $XXXXXXXXXX on XXXXXXXXXX or such later agreed date. 4. ...
Ruling
2003 Ruling 2003-0012293 - Loss Utilization in a Related Group
The rulings are virtually identical except that in this ruling the dividend rate on the preferred shares exceeds the interest rate on the loan by XXXXXXXXXX % whereas in the prior ruling the dividend rate on the preferred shares is equal to the interest rate on the loan. ...
Ruling
2003 Ruling 2002-0162673 - Butterfly
The original shareholdings of DC on incorporation were as follows: Shareholder Number of shares % Class of shares Stated capital W XXXXXXXXXX "A" $XXXXXXXXXX S XXXXXXXXXX "A" $XXXXXXXXXX 8. ...
Ruling
2004 Ruling 2003-0049423 - Split-Up Butterfly
M Class A Preference XXXXXXX XXXXXXX XXXXXXX Bco Common XXXXXXX XXXXXXX XXXXXXX Cco Common XXXXXXX XXXXXXX XXXXXXX The Class A Preference shares of Aco are non-voting, redeemable, retractable for an amount of $XXXXXXXXXX and entitled to non-cumulative dividends at the rate of XXXXXXXXXX % per annum of the redemption amount. ...
Ruling
2003 Ruling 2003-0009513 - PARTNERSHIP - WIND-UP
The General Partner will receive an undivided XXXXXXXXXX% interest in the preferred shares distributed, and the Limited Partners will receive an undivided XXXXXXXXXX % interest in the preferred shares distributed. 40. ...
Ruling
2003 Ruling 2003-0034663 - COMMUNITY SMALL BUSINESS
CCo's subscription amount will be $XXXXXXXXXX and its subscription will represent approximately XXXXXXXXXX % of all the issued shares of the Fund. ...
Ruling
2004 Ruling 2003-0050081R3 - interest deductibility
Canco owns approximately XXXXXXXXXX % of the shares of the capital stock of Foreign Affiliate #2, which is a controlled foreign affiliate of Canco. ...
Ruling
2004 Ruling 2003-0051381R3 - Steps to avoid gain - 21 yr
Position: 1 & 2. Yes. 3. Provided that the trustee does not elect under subsection 107(2.001), yes. 4. ...