Search - 包建铎违纪违法案件以案促改以案促治专题组织生活会 个人对照检查

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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. ...
Miscellaneous severed letter

2001 Income Tax Severed Letter 2001-0089511 - Split - Up Butterfly

This ruling replaces and rescinds Ruling # 2000- 004652, dated XXXXXXXXX, 2001. ...
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. ...
Ruling

1999 Ruling 9905033 - BUTTERFLY REORGANIZATION

XXXXXXXXXX owns XXXXXXXXXX units of XXXXXXXXXX, representing approximately XXXXXXXXXX % of the XXXXXXXXXX issued and outstanding units of XXXXXXXXXX, In XXXXXXXXXX announced its intention to commence normal course purchases of units of XXXXXXXXXX through the facilities of XXXXXXXXXX. ...
Ruling

1999 Ruling 9902483 - BUTTERFLY RULING

The share capital of each new corporation will consist of: (a) a class of common shares; and (b) a class of special shares designated as Class A special shares with the following share attributes: (i) voting; (ii) redeemable and retractable at a redemption amount ("Redemption Amount") of $XXXXXXXXXX per share; (iii)for the purpose of subsection 191(4) of the Act, the terms and conditions of the Class A special shares to be issued as described in paragraph 15 below will, at the time of their issue, specify $XXXXXXXXXX per share as the amount for which the share is to be redeemed, acquired or cancelled which amount will be equal to the fair market value of the property received by the particular new corporation as consideration for such share; (iv) entitled to an annual non-cumulative dividend, not to exceed xxxxxxxxxx % per annum of their Redemption Amount, to be paid at the discretion of the directors of the particular new corporation; and (v) the stated capital of these special shares will be determined on the date of issuance. 6. ...

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