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

Unless otherwise stated, statutory references in this letter are to the Act; "adjusted cost base" (also "ACB") has the meaning assigned by section 54; "controlled foreign affiliate" has the meaning assigned by subsection 95(1); "capital property" has the meaning assigned by section 54; "dividend rental arrangement" has the meaning assigned by subsection 248(1); " FMV" means fair market value; "guarantee agreement" has the meaning assigned by subsection 112(2.2); XXXXXXXXXX "paid-up capital" has the meaning assigned by subsection 89(1); "proceeds of disposition" has the meaning assigned by section 54; "public corporation" has the meaning assigned by subsection 89(1); "stated capital" has the meaning assigned by the XXXXXXXXXX; "taxable Canadian corporation" has the meaning assigned by subsection 89(1); "taxable dividend" has the meaning assigned by subsection 89(1); and "unrelated person" has the meaning assigned by subsection 55(3.01). ...

In XXXXXXXXXX, Dco acquired all of the XXXXXXXXXX was the subject matter of an advance income tax ruling # XXXXXXXXXX issued by the CCRA on XXXXXXXXXX. 13. ...

Consolidated revenues of I Ltd. for the year ended XXXXXXXXXX totaled US $ XXXXXXXXXX with consolidated net earnings amounting to US $XXXXXXXXXX. 5. ...

Under the terms of the Settlement Agreement agreed to by the initial executors and trustees of the Estate, the Late Wife, Child A, Child B and the Charity: (a) cash payments of $XXXXXXXXXX and $XXXXXXXXXX were to be made by the Estate to Child A and Child B, respectively; and (b) the Charity agreed to pay to Child A XXXXXXXXXX % of the value of the assets it receives from the Estate. ...

The foregoing computation of the purchase price per Unit payable by ParentCo in shares of its capital stock is subject to subsection 25(3) of the CBCA, which provides: " A share shall not be issued until the consideration for the share is fully paid in money or in property or past services that are not less in value than the fair equivalent of the money that the corporation would have received if the share had been issued for money. ...

Principal Issues: 1. whether LP Units are tax shelters 2. whether existence of call option causes no REOP 3. whether existence of call option is 96(2.2)(d) benefit 4. whether gaar applies 5. whether, where a trust receives mixed income (split and nonsplit), trust may designate payments to beneficiaries Position: 1. no 2. not in and of itself 3. not in and of itself 4. maybe, if call option is exercised and 24 month period in 110.6(2.1) avoided 5. yes, as long as nonsplit income allocated to beneficiaries does not exceed non-split income of trust Reasons: 1. limited partners cannot receive cumulative losses that are greater than XXXXXXXXXX % of their capital contribution 2. must consider all facts re REOP 3. call option is at discretion of general partner, not limited partners/ option price is fmv 4. 110.6 5. law does not prohibit streaming or require equal payouts of split and nonsplit income XXXXXXXXXX 2001-006921 XXXXXXXXXX, 2001 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX We are writing in response to your letter of XXXXXXXXXX, wherein you requested an advance income tax ruling, and your subsequent correspondence and our (XXXXXXXXXX) telephone discussions concerning this ruling request. ...

.), as amended, and unless otherwise stated, every reference herein to a section, subsection, paragraph or subparagraph is a reference to the relevant provision of the Act; (b) "adjusted cost base" (also referred to as "ACB") has the meaning assigned by section 54; (c) "agreed amount" in respect of property means the amount that the transferor and the transferee of the property have agreed upon in their election under subsection 85(1) in respect of the property; (d) "BCA" means the "Canada Business Corporations Act "; (e) "capital dividend" has the meaning assigned in subsection 83(2); (f) "capital dividend account" (also referred to as "CDA") has the meaning assigned by subsection 89(1); (g) "capital property" has the meaning assigned by section 54; (h) "cost amount" has the meaning assigned by subsection 248(1); (i) "dividend refund" has the meaning assigned by subsection 129(1); (j) "eligible property" has the meaning assigned by subsection 85(1.1); (k) "Mr.A" refers to the late XXXXXXXXXX; (l) "Mrs. ...

In general, this means that XXXXXXXXXX % of an Eligible Director's retainer fees for a year and meeting fees for meetings held within a Quarter in that year become payable at the end of the Quarter. ...

If the Eligible Director elects to participate in the Plan, he or she may choose to receive: (i) XXXXXXXXXX%, (ii) XXXXXXXXXX %, (iii) XXXXXXXXXX% or (iv) XXXXXXXXXX% of his or her Directors' Annual Remuneration in DSUs under the Plan, with the remainder (if any) of such Directors' Annual Remuneration to be paid in cash, net of the applicable withholding taxes, to the Eligible Director. ...

The capital gain on the deemed disposition of XXXXXXXXXX shares at the time of death was $ XXXXXXXXXX and the adjusted cost base of the XXXXXXXXXX Holdings Class A shares to the Estate is $XXXXXXXXXX. ...