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Ruling
2011 Ruling 2009-0307841R3 - Oil Sands Project
Predecessor 2 initially owned a XXXXXXXXXX % interest in the Partnership. ... Following this sale, the Corporation owns a XXXXXXXXXX % interest in the Partnership and XXXXXXXXXX owns the remaining XXXXXXXXXX % interest. 8. As a result of the restructuring described in paragraph 3, the Corporation also owns a XXXXXXXXXX % interest inXXXXXXXXXX as well as aXXXXXXXXXX % interest inXXXXXXXXXX. ...
Ruling
2003 Ruling 2002-0165313 F - ACTIVITE COMMERCIALE COMPLEMENTAIRE
Elle a été enregistrée sous le nom de " XXXXXXXXXX ". 2. Entité A a été constituée par lettres-patentes émises en vertu des lois XXXXXXXXXX. 3. ... Pour faciliter le démarrage de nouvelles entreprises, le financement sera généralement fait sous forme de débentures remboursables à des modalités commercialement avantageuses pour des montants par entreprise privée pouvant généralement varier entre XXXXXXXXXX $ et XXXXXXXXXX $. ...
Ruling
2005 Ruling 2005-0139911R3 - Supplemental Ruling
In Subparagraph 24(a), add the following to the end of this subparagraph: ", provided that if the termination or winding up of the Fund occurs prior to the end of the XXXXXXXXXX Period, the Class B Exchange Formula described in paragraph 22 will be adjusted so that A equals the average quarterly per unit cash distributions paid on the Class B Units after the Closing Date;". 4. ... Specifically, the number of Class A Units for which such Series 2 Exchangeable Shares may be redeemed will be determined by the following formula: A × C × D B 1. 1. 1. 1. where: A = the average quarterly per unit cash distributions paid on the Class B Units for the XXXXXXXXXX period ending on the last day of the fiscal quarter immediately preceding such time; B = the amount of $XXXXXXXXXX per share, being XXXXXXXXXX times the Monthly Target, the target average quarterly per unit distributions payable on the Class B Units; C = the number of Series 2 Exchangeable Shares being redeemed in consideration for Class A Units by the holders of Series 2 Exchangeable Shares at that time; and D = the Series 2 Exchange Ratio then in effect; provided that the Series 2 Exchangeable Shares may not, in any event, be redeemable for Class A Units on the basis of a ratio that is higher than the Series 2 Exchange Ratio then in effect. ...
Ruling
16 August 1989 Ruling 74201 F - Maximum Tax Actuarial Reserves on Reinsurance Risk
16 August 1989 Ruling 74201 F- Maximum Tax Actuarial Reserves on Reinsurance Risk Unedited CRA Tags 138(12) maximum tax actuarial reserve, 138(12) life insurance policy in Canada, ITR 1401, 1400 August 16, 1989 E.H. ... There are two questions to be examined in reviewing this situation. 1. ... 2. Is a life insurance policy, issued on the life of a non-resident, eligible for life-type reserves under Regulation 1401? ...
Ruling
1999 Ruling 9920043 F - PAPILLON
Les autres biens (au sens du paragraphe 248(1)) possédés par PORTCO en date du XXXXXXXXXX étaient composés d'un dépôt à terme de XXXXXXXXXX $, et d'une encaisse et de sommes à recevoir d'un montant total d'environ XXXXXXXXXX $. Les dettes de PORTCO en date du XXXXXXXXXX étaient composées seulement de comptes fournisseurs et frais courus d'un montant total d'environ XXXXXXXXXX $. 3. ...
Ruling
2010 Ruling 2009-0347301R3 - Does s.s. 13(21.2) apply on s.s. 98(5) rollover
LPCo and the GPCo hold respectively XXXXXXXXXX % (XXXXXXXXXX units) and XXXXXXXXXX % (XXXXXXXXXX units) of the LP Units. 5. ...
Ruling
2018 Ruling 2018-0778931R3 - 55(3)(a) Reorganization
On XXXXXXXXXX, DC resolved to increase the amount in the stated capital account – and consequently, the PUC – of the DC Class C Shares by $XXXXXXXXXX (that is, an amount equal to the amount by which the redemption amount of the DC Class C Shares exceeded their PUC prior to the PUC increase). ...
Ruling
2016 Ruling 2015-0617351R3 - payments under a German profit transfer agrmt “PTA"
The share ownership of FA3 is outlined in the table below: Holder of Number Share capital % of share Number of % of votes FA3 Shares of Shares XXXXXXXXXX capital votes FA2 XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Total XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX 7. ... The share ownership of FA5 is outlined in the table below (according to the articles of association of FA5 each XXXXXXXXXX of share capital participation grants one vote): Holder of Number Share capital % of share Number of % of votes FA5 Shares of Shares XXXXXXXXXX capital votes KG XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX FA2 XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX FA3 XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX FA4 XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Total XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX 10. ... Following the changes to the shareholder rights as outlined in paragraphs 21, 22 and 23, the share ownership of FA5 will be as follows: Holder Class of Number Share % of Number of % of of FA5 shares of shares capital share votes votes Shares XXXXX capital KG Preferred XXXXX XXXXX XXXXX XXXXX XXXXX Shares New FA3 Ordinary XXXXX XXXXX XXXXX XXXXX XXXXX Shares Total XXXXX XXXXX XXXXX XXXXX XXXXX 25. ...
Ruling
2012 Ruling 2012-0452821R3 - Forgiveness of debt
C-44, as amended; (r) "CDN$" or "$" means Canadian dollars; (s) "CEC" means cumulative eligible capital and has the meaning assigned by subsection 14(5) of the Act; (t) "Certificate" means the certificate of arrangement giving effect to the Arrangement; (u) "Circular" means the management proxy circular regarding, inter alia, the Recapitalization, distributed to Securityholders in connection with the Shareholders' Meeting and the Debtholders' Meeting; (v) "Commercial debt obligation" has the meaning assigned in subsection 80(1) of the Act; (w) "Commercial obligation" has the meaning assigned in subsection 80(1) of the Act; (x) "Convertible Debentures" has the meaning specified in 19 below; (y) "Convertible Debenture Indenture" means the trust indenture, dated XXXXXXXXXX, among Aco, Y Income Fund, Y Trust and the BNY Trust Company of Canada in respect of the Convertible Debentures, as supplemented by the first supplemental trust indenture dated XXXXXXXXXX between Aco and the BNY Trust Company of Canada; (z) "Court" means the XXXXXXXXXX; (aa) "Cco" means XXXXXXXXXX; (bb) "Cco Notes" has the meaning assigned in 14 below; (cc) "CRA" means the Canada Revenue Agency; (dd) "Credit Agreement" means the second amended and restated credit agreement, dated XXXXXXXXXX, including, inter alia, Aco, as borrower, the XXXXXXXXXX and the Lenders, as defined in the Credit Agreement, as amended; (ee) "Cumulative Redeemable First Preferred Shares" means, collectively, the Series 1 Redeemable First Preferred Shares, the Series 2 Redeemable First Preferred Shares, the Series 3 Redeemable First Preferred Shares, the Series 4 Redeemable First Preferred Shares, the Series 5 Redeemable First Preferred Shares, the Series 6 Redeemable First Preferred Shares and the Series 7 Redeemable First Preferred Shares of Aco; (ff) "Dco" means XXXXXXXXXX; (gg) "Debtholders" means holders of the Affected Unsecured Debt; (hh) "Debtholders' Meeting" means the meeting of Debtholders that will be held pursuant to an Interim Order of the Court to consider and, if advisable, to approve the Arrangement and to consider such other matters as may properly come before such meeting; (ii) "Disposition" has the meaning assigned by subsection 248(1) of the Act; (jj) "Effective Date" means the date showing on the Certificate stating the date on which the Plan of Arrangement becomes effective in accordance with the CBCA; (kk) "Existing Common Shareholders" means the holders of Existing Common Shares; (ll) "Existing Equity Securities" has the meaning specified in 10 below; (mm) "Existing Shareholders" means the holders of the Existing Equity Securities; (nn) "Final Order" means the final order of the Court approving the Arrangement as such order may be amended at any time prior to the Effective Date or, if appealed, then unless such appeal is withdrawn or denied, as granted or affirmed; (oo) "FMV" means fair market value; (pp) "Forgiven amount" has the meaning assigned by subsection 80(1) of the Act; (qq) "Interim Order" means the interim order of the Court to be issued, pursuant to section 192 of the CBCA, as the same may be amended; (rr) "Laws" means all statutes, codes, regulations, statutory rules, orders, decrees, published policies, published guidelines and terms and conditions of any grant of approval, permission, authority or license of any governmental authority, and the term "applicable" with respect to such Laws, and in the context that refers to one or more Persons, means that such Laws apply to such Person or Persons or its or their business, undertaking, property or securities and emanate from a governmental authority having jurisdiction over the Person or Persons or its or their business, undertaking, property or securities (all references herein to a specific statute being deemed to include all applicable rules, regulations, rulings, orders and forms made of promulgated under such statute and the published policies and published guidelines of the governmental authorities administering such statute); (ss) "Medium Term Notes" means the notes described in 16 below; (tt) "MTN Indenture" means the trust indenture, dated XXXXXXXXXX, among XXXXXXXXXX, Y Income Fund and Bco, in respect of the Medium Term Notes, as supplemented by the first supplemental trust indenture dated XXXXXXXXXX among Aco, Bco and XXXXXXXXXX; (uu) "Mco" means XXXXXXXXXX, further described in 13 below; (vv) "MLP" means XXXXXXXXXX; (ww) "Newco1" means XXXXXXXXXX, a newly incorporated wholly-owned subsidiary of Aco incorporated under the CBCA; (xx) "New Aco" means XXXXXXXXXX, a new corporation incorporated under the CBCA; (yy) "New Aco Common Shares" means the common shares in the capital of New Aco to be created and issued in connection with the Recapitalization; (zz) "New Employee Incentive Plan" means the new employee incentive plan, the principal terms of which are described in a supplement to the Plan of Arrangement; (aaa) "Non-capital losses" has the meaning assigned by subsection 111(8) of the Act; (bbb) "Options" means the outstanding options issued under the XXXXXXXXXX Stock Option Plan of Aco and the XXXXXXXXXX Stock Option Plan of Aco; (ccc) "Order" means any order of the Court in these proceedings including, without limitation, the Interim Order and the Final Order; (ddd) "Paid-up capital" has the meaning assigned by subsection 89(1) of the Act; (eee) "Person" means any individual, firm, partnership, joint venture, venture capital fund, association, trust, trustee, executor, administrator, legal personal representative, estate, group, body corporate (including a limited liability company and an unlimited liability company), corporation, unincorporated association or organization, governmental authority, syndicate or other entity, whether or not having legal status; (fff) "Plan of Arrangement" means the plan of arrangement in respect of the Arrangement, a draft of which will be appended to the Circular; (ggg) "Proceeds of Debtholder Exchange" has the meaning specified in 45 below; (hhh) "Proposed Transactions" means the proposed transactions described from 41 to 46 below; (iii) "Public corporation" has the meaning assigned by subsection 89(1) of the Act; (jjj) "Recapitalization" means the transactions contemplated by the Plan of Arrangement; (kkk) "Record Date" means the date for determining those Securityholders entitled to receive notice and to vote at the Shareholders' Meeting and the Debtholders' Meeting; (lll) "Related" has the meaning assigned by subsection 251(2) of the Act; (mmm) "RSUs" means the outstanding restricted share units issued under the Restricted Share Unit Plan of Aco; (nnn) "Securityholders" means the Debtholders and Existing Shareholders; (ooo) "Series 1 Redeemable First Preferred Shares" means the preferred shares of Aco described in 3 below; (ppp) "Series 2 Redeemable First Preferred Shares" means the preferred shares of Aco described in 4 below; (qqq) "Series 3 Redeemable First Preferred Shares" means the preferred shares of Aco described in 5 below; (rrr) "Series 4 Redeemable First Preferred Shares" means the preferred shares of Aco described in 6 below; (sss) "Series 5 Redeemable First Preferred Shares" means the preferred shares of Aco described in 7 below; (ttt) "Series 6 Redeemable First Preferred Shares" means the preferred shares of Aco described in 8 below; (uuu) "Series 7 Redeemable First Preferred Shares" means the preferred shares of Aco described in 9 below; (vvv) "Shareholders' Meeting" means the meeting of the Existing Shareholders to be held pursuant to the CBCA and to the Interim Order to consider and, if advisable, to approve the Arrangement and to consider such other matters as may properly come before such meeting; (www) "TCC" means taxable Canadian corporation and has the meaning assigned by subsection 89(1) of the Act; (xxx) "TSO" means a CRA tax services office; (yyy) "UCC" means undepreciated capital cost and has the meaning assigned by subsection 13(21) of the Act; (zzz) "US$" or "U.S. dollars" means United States dollars; (aaaa) "Wco" means XXXXXXXXXX, a corporation described in 28 below; (bbbb) "Yco" means XXXXXXXXXX, a predecessor corporation of Aco (before the amalgamation of XXXXXXXXXX, Yco and XXXXXXXXXX), and previously designated as XXXXXXXXXX prior to the change of name undertaken on XXXXXXXXXX; (cccc) "Y Income Fund" means XXXXXXXXXX; (dddd) "Y LLC" means XXXXXXXXXX, the corporation described in 26 below; (eeee) "Y Trust" means XXXXXXXXXX; (ffff) "YUSco" means XXXXXXXXXX, the corporation described in 26 below; (gggg) YUS Note" has the meaning given to it in 27 below; (hhhh) XXXXXXXXXX; (iiii) XXXXXXXXXX; (jjjj) XXXXXXXXXX; (kkkk) "XXXXXXXXXX Note" has the meaning given to it in 29 below; Unless otherwise noted, all references to currency are to Canadian dollars STATEMENT OF FACTS 1. ... Prior to the Proposed Transactions, Aco has the following Medium Term Notes (collectively referred to as the "Medium Term Notes") issued and outstanding: Series Principal Amount Interest Rate Maturity Series 2 $ XXXXXXXX XXXXXXXXX% XXXXXXXXXX Series 3 $ XXXXXXXX XXXXXXXXX% XXXXXXXXXX Series 4 $ XXXXXXXX XXXXXXXXX% XXXXXXXXXX Series 5 $ XXXXXXXX XXXXXXXXX% XXXXXXXXXX Series 7 $ XXXXXXXX XXXXXXXXX% XXXXXXXXXX Series 8 $ XXXXXXXX XXXXXXXXX% XXXXXXXXXX Series 9 $ XXXXXXXX XXXXXXXXX% XXXXXXXXXX Series 10 $ XXXXXXXX XXXXXXXXX% XXXXXXXXXX The terms and conditions of the Medium Term Notes are governed by the MTN Indenture. ...
Ruling
1998 Ruling 9828673 F - VENTE D'ACTIONS
Les actions privilégiées donnent droit à un dividende fixe non cumulatif de XXXXXXXXXX $ par action, et sont rachetables au gré de la société à leur valeur nominale de XXXXXXXXXX $ par action. ... Le capital versé au sens du paragraphe 89(1) des actions ordinaires d'OPCO est de XXXXXXXXXX $, soit XXXXXXXXXX $ par action. ... Il souscrira à une action ordinaire de NOUCO pour une considération de XXXXXXXXXX $. 18. ...