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Ruling
2004 Ruling 2003-0052973 - Carrying on business in Canada
The aggregate fair market value of the capital notes will at all times not exceed XXXXXXXXXX % of the aggregate fair market value of all shares in the capital stock and all debt obligations of XXXXXXXXXX then outstanding. ...
Ruling
2004 Ruling 2003-0047281R3 - Interest and an amalgamation
The XXXXXXXXXX ("XCo"), which owned approximately XXXXXXXXXX % of the outstanding Target Shares (approximately XXXXXXXXXX% on a fully diluted basis) irrevocably agreed to deposit all of the Target Shares it owned to Offeror. ...
Ruling
2004 Ruling 2003-0047141R3 - Deferred Bonus Plan - 248(1)(k) SDA
Yours truly, XXXXXXXXXX for Director Financial Industries Division Income Tax Rulings Directorate Policy & Planning Branch ...
Ruling
2004 Ruling 2004-0060201R3 - XXXXXXXXXX First Nation Ruling
XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...
Ruling
2000 Ruling 2000-0021013 - SDA PARAGRAPH K EXCLUSION
These rulings are given subject to the limitations and qualifications set forth in Canada Customs & Revenue Agency (the "Agency") Information Circular 70-6R3 dated December 30, 1996, and are binding upon the Agency provided the Plan is implemented on or before XXXXXXXXXX. ...
Ruling
2000 Ruling 2000-0041363 - Allocation of Gains to Redeeming Unitholders
Position TAKEN 1) Yes 2) No 3) No Reasons FOR POSITION TAKEN The position taken with respect to the allocation of capital gains to redeeming unitholders and for determining the proceeds of disposition on such redemptions is consistent with the position taken in a previous ruling (Doc # 981758). ...
Ruling
2001 Ruling 2000-0055463 - pension plan
It is anticipated that the transfer agreement referred to in 7 above will contemplate that the transfer of assets to the XXXXXXXXXX Funds may need to occur in more than one stage although a substantial (over XXXXXXXXXX % on a market value basis) portion of the assets likely will be transferred at one stage following the obtaining of regulatory approval. ...
Ruling
2001 Ruling 2001-007262C - FILM PARTNERSHIP/UK TREATY
The UK Co-Producer will receive an up-front advance (the "Advance") from the Film Partnership, representing approximately XXXXXXXXXX % of the Rights Payment. ...
Ruling
2001 Ruling 2001-0086113 - SUPPLEMENTARY UNFUNDED PENSION
The Employer's annual contributions to the RPP are set out in the RPP and are XXXXXXXXXX% of a Member's Earnings up to the YMPE plus XXXXXXXXXX % of the Member's Earnings in excess of the YMPE. 4. ...
Ruling
2001 Ruling 2001-0092683 - PHANTOM STOCK PLAN EMPLOYEE BONUSES
Yours truly, XXXXXXXXXX for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...