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

More specifically: Aco establishes a new sister to Bco (Newco) to which Aco does an s. 85(1) drop-down of preferred shares of Bco having a fair market value equaling that of the trademarks; Bco spins-off the trademarks to Newco on a partial rollover basis in consideration for prefs of Newco, thereby using Bco’s net capital losses to effect a ½ step-up of the UCC of the trademarks under s. 13(7)(e)(ii) – and with Newco licensing the trademarks back to Bco for royalties; The prefs in 1 and 2 above are cross-redeemed (with reliance on the s. 55(3)(a) exception to s. 55(2)); Newco is wound-up under s. 88(1); Aco does an s. 85(1) drop-down of the trademarks back to Bco, but choosing an elected amount so as to uses up its net capital losses and to effect a further ½ step-up of the trademarks' UCC under s. 13(7)(e)(ii). ...

New structure: Common Shareholders of Newco (following the entering into of a shareholders' agreement many of whose terms are similar to the former Partnership Agreement) will have the option of providing their services personally or by using a "New Contracting Corporation" which is owned by, and is the employer of, him or her – except that preference shares may be held by family members – so that each New Contracting Corporation will provide services for agreed fees, will be responsible for specified expenses such as professional membership fees, insurance premiums, education expenses, travel expenses and entertainment expenses (with Newco to provide each New Contracting Corporation with certain supplies, facilities and equipment but with their fair market value to be borne by the New Contracting Corporation), and with the New Contracting Corporation free to compete with Newco. ...

The DSI of the transferor corporation (“Transferor”) that has accrued on the shares of its capital stock held by shareholders other than the transferee corporation (“Transferee”), determined immediately after the reorganization, will be calculated in accordance with the following formula: DSI on shares of capital stock of Transferor held by all shareholders immediately after the reorganization = DSI immediately before the reorganization X total net cost amount of property retained by Transferor / total net cost amount of all property of Transferor immediately before the reorganization. ...

Ruling that the transfers from the Direct Subtrusts to Trust A in 2 will not be considered a "disposition" by virtue of s. 248(1) – disposition, (f)(v), and Trust A will be deemed, to be the same trust as, and a continuation of, each of the Direct Subtrusts by virtue of s. 248(25.1); therefore the ACB of Taxpayer's interest in Trust A will be equal to the aggregate ACB of Taxpayer's interests in the Direct Subtrusts before the transfer. See detailed summary under s. 132.2 – qualifying exchange. ...

See detailed summary under s. 132.2 – qualifying exchange. ...

. … Opco may advance funds to the LP from time to time for working capital and development… on arm's length commercial terms…. ...

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