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Ruling

2096 Ruling 9601653 - DISTRESSED PREFERRED SHARES

Because the financial affairs of XXXXXXXXXX are inextricably linked with each other through the pooling of cash flows, intercorporate loans & guarantees and incurring and reallocating of common costs, this group of companies, along with any other directly or indirectly owned subsidiaries, are herein collectively referred to as "XXXXXXXXXX" for the purposes of this letter, except where otherwise noted. 5. ...
Ruling

2003 Ruling 2003-0184493 - PHANTOM STOCK PLANS

Their account numbers are as follows: Company CCRA Account # XXXXXXXXXX 3. ...
Ruling

2000 Ruling 2000-0002583 - Paragraph 88(1)(c), Section 245

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayers or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ...
Ruling

2001 Ruling 2000-0061353 - XXXXXXXXXX

The General Partner is entitled to XXXXXXXXXX % of the profits and losses of the Partnership, as well as the capital of the Partnership in the event of dissolution. 21. ...
Ruling

1999 Ruling 9918313 - REORGANIZATION

The holder of Canco 2 Common Shares will be entitled to one (1) vote for each Canco 2 Common Share so held; and (b) one (1) non-voting, redeemable and retractable preferred share which shall be entitled to receive, as and when declared from time to time by the board of directors, non-cumulative dividends not exceeding an amount equal to XXXXXXXXXX % per annum calculated on the Canco 2 Special Share Redemption Amount (as hereinafter defined) (the "Canco 2 Special Share"). ...
Ruling

2001 Ruling 2000-0059543 - ASSUMPTION OF DEBT FOR ASSETS

The notes bear interest at the rate of XXXXXXXXXX % per annum (payable semi-annually) and mature on XXXXXXXXXX (the "XXXXXXXXXX Debentures"); f) Pursuant to unsecured notes in the principal amount of US $XXXXXXXXXX issued by PARENT on XXXXXXXXXX under the XXXXXXXXXX Indenture. ...
Ruling

2002 Ruling 2002-0158353 - Butterfly transaction-Papillon

For the purpose of determining the Agreed Amount of the depreciable property of a prescribed class, the reference to "... the undepreciated capital cost to the taxpayer of all property of that class immediately before the disposition... ...
Ruling

1999 Ruling 9922493 - LIMITED PARTNERSHIP - FILM FINANCING

Investors may choose to finance up to approximately XXXXXXXXXX % of their investment in Units by way of a Unit Loan from the Unit Lender. ...
Ruling

2000 Ruling 1999-0010783 - Spin-off butterfly; treaty exemption

In either case, on a diluted basis, the public or such party or parties will own less than 50 % of the issued and outstanding voting shares in the capital of PublicCo. ...
Ruling

2000 Ruling 2000-0011353 - Butterfly Arrangement

To the best of the knowledge of the directors and senior officers of Canco, as of the date hereof, no person or group of related persons beneficially owns, directly or indirectly, more than ten percent of the issued and outstanding common shares of Canco, except XXXXXXXXXX who holds approximately XXXXXXXXXX % of Canco's issued common shares either directly or through XXXXXXXXXX ("Xco") a private company which is wholly-owned by him. 8. ...

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