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Ruling

2010 Ruling 2009-0347041R3 - Loss Consolidation

X owns XXXXXXXXXX common shares (XXXXXXXXXX %) and a group of employees of Amalco and its affiliates, together, owns XXXXXXXXXX common shares (XXXXXXXXXX %). ... The New Debenture Loan matures XXXXXXXXXX years after its issuance and bears interest at XXXXXXXXXX %. ... Simple interest will accrue on the Lossco Loan and will be calculated at a rate of XXXXXXXXXX %. ...
Ruling

2010 Ruling 2010-0360501R3 - Article IV(7)(b) and PUC Increase

Canco owns a XXXXXXXXXX % partnership interest in LP. LP is treated as a partnership under the taxation laws of the United States (i.e. it is a fiscally transparent entity). 10. Canco3 owns a XXXXXXXXXX % partnership interest in LP. 11. USCO2 was incorporated under the XXXXXXXXXX. ... Yours truly, XXXXXXXXXX For Director International & Trust Division Income Tax Rulings Directorate ...
Ruling

2008 Ruling 2008-0280131R3 - Interest exempt from tax

Aco owns a XXXXXXXXXX % undivided interest in the Project. This undivided interest is its sole business asset. 3. ... Interest will be charged at a rate equal to LIBOR plus a margin of XXXXXXXXXX % per annum payable quarterly on XXXXXXXXXX of each year. 10. ... Aco will be required to pay Parentco a guarantee fee of XXXXXXXXXX % per annum, calculated on the basis of a year of XXXXXXXXXX days and the actual number of days elapsed on the amount used under the Credit Facility, representing a charge by Eco to Parentco for guaranteeing the Loan between Parentco and Finco. 14. ...
Ruling

2003 Ruling 2003-0042843 - UNFUNDED SUPPLEMNTAL PENSION PLAN

The Association is introducing a supplemental employee retirement plan ("SERP"), entitled "XXXXXXXXXX" (the "Plan"), for public sector employers that are concurrently Association members and participants in the Association's registered defined benefit pension plan named XXXXXXXXXX (CCRA registration # XXXXXXXXXX) (the "DBPP"). ... A summary of the Plan terms follows: a) Eligibility: Employees designated by the employer to be a member of the Plan. b) Contributions: No member shall contribute to the Plan nor shall there be any employer pre-funding. c) Pension Benefit at Normal Retirement: If retirement occurs at age XXXXXXXXXX or where age plus credited service is equal to at least XXXXXXXXXX ("Rule of XXXXXXXXXX"), an unreduced annual pension is payable equal to: XXXXXXXXXX % of the member's average best XXXXXXXXXX consecutive years' earnings times credited service commencing XXXXXXXXXX, payable in the normal form, plus for eligible pensionable service during the period XXXXXXXXXX through XXXXXXXXXX (maximum XXXXXXXXXX years) XXXXXXXXXX% of the member's average best XXXXXXXXXX years' earnings up to the average of the years maximum pensionable earnings for the year of retirement and the preceding four years, plus XXXXXXXXXX % of the member's excess average best XXXXXXXXXX years earnings payable under the normal form less the member's DBPP and XXXXXXXXXX PP pensions based on the normal form. d) Early Retirement: Upon attainment of age XXXXXXXXXX, the member's accrued pension is reduced by XXXXXXXXXX% times the lesser of: the number of years by which the "rule of XXXXXXXXXX" exceeds the member's age and credited service, and the number of years by which the member's retirement age precedes age XXXXXXXXXX. e) Normal Form of Pension: The Plan normal form is identical to the DBPP normal form: for a member with a spouse at retirement, a joint and survivorship XXXXXXXXXX% form for a member without a spouse at retirement, a life annuity guaranteed for ten years. f) Death Before Retirement: A member's spouse is entitled to receive the commuted value of the member's accrued pension, or an immediate or deferred pension provided by such commuted value. ...
Ruling

30 November 1995 Ruling 9634883 - PUBLIC COMPANY BUTTERFLY

General Facts Relating to the XXXXXXXXXX Business XXXXXXXXXX The partners in the XXXXXXXXXX Partnership, together with their respective ACB’s in their partnership interests, are set forth below: Anticipated Partnership ACB as at ACB as at Interest XXXXXXXXXX $ $ XXXXXXXXXX The interest in the XXXXXXXXXX Partnership held by each of XXXXXXXXXX was held by the particular partner on February 22, 1994 and has been an excluded interest, within the meaning of subsection 40(3.15), continuously since that time. ... The outstanding common shares of XXXXXXXXXX owned by XXXXXXXXXX currently have a nominal FMV of $XXXXXXXXXX and following the proposed transfer of the shares of XXXXXXXXXX and the shares of XXXXXXXXXX (currently owned by XXXXXXXXXX) to XXXXXXXXXX, as described in Paragraph 39, will continue to have a nominal FMV of $XXXXXXXXXX Associated Corporations The XXXXXXXXXX Group owns the following share interests in the Associated Corporations: Percentage of Outstanding Estimated Shares Held ACB FMV $ $ XXXXXXXXXX FMV of the shares of the Associated Corporations, other than XXXXXXXXXX, is based on the closing share price on the relevant stock exchange on XXXXXXXXXX. ... Immediately after the share for share exchange described herein, the FMV of each XXXXXXXXXX Shareholder's shares of the capital stock of Newco1 will be equal to or approximate the amount determined by the formula (A x B) + D C as found in subparagraph (b)(iii) of the definition of "permitted exchange" in subsection 55(1) of the Act. ...
Ruling

2008 Ruling 2007-0256851R3 - Partnership Reorg-Personal Services Business

(w) "Partnership" means the partnership, which currently carries on the Practice under the firm name and style of "XXXXXXXXXX ", a registered partnership pursuant to the laws of the Province; (x) "Partnership Agreement" means the agreement governing the business activities of the Partnership. ... Part-time Partners share in the net income or loss of the Partnership on a pro-rated basis; (g) the Partnership may make a cash call on Partners to fund losses or to return any excess net income paid out to Partners with the affirmative vote of XXXXXXXXXX % of the Partners present at a meeting of Partners. ... Repayment of the capital account is to be paid in no more than XXXXXXXXXX equal monthly payments without interest unless accelerated payment is approved by XXXXXXXXXX % of the Partners (excluding the retiring Partner) in person at a meeting of Partners; 6. ...
Ruling

2012 Ruling 2011-0431481R3 - Short-term and Taxable Preferred Share

The provisions referred to in 3 above further provide that the Variable Voting Shares are entitled to one vote per Variable Voting Share unless (i) the number of Variable Voting Shares outstanding, as a percentage of the total number of voting shares outstanding exceeds XXXXXXXXXX % or (ii) the total number of votes cast by or on behalf of holders of Variable Voting Shares at any meeting exceeds XXXXXXXXXX % of the total number of votes that may be cast at such meeting. If either of the above-noted thresholds would otherwise be surpassed at any time, the vote attached to each Variable Voting Share will decrease proportionately such that (i) the Variable Voting Shares as a class do not carry more than XXXXXXXXXX % of the aggregate votes attached to all issued and outstanding voting shares of the Corporation and (ii) the total number of votes cast by or on behalf of holders of Variable Voting Shares at any meeting does not exceed XXXXXXXXXX % of the votes that may be cast at such meeting. ... The Corporation's remaining assets currently consist of an approximately XXXXXXXXXX % equity interest (as at XXXXXXXXXX) in, and XXXXXXXXXX warrants for the purchase of additional XXXXXXXXXX voting shares of the Subsidiary and a significant amount of cash and cash equivalents (approx. ...
Ruling

2008 Ruling 2008-0266221R3 - Loss utilization

Cco is the beneficial owner of XXXXXXXXXX % of the issued and outstanding shares of Yco. 11. Bco is the beneficial owner of XXXXXXXXXX % of the issued and outstanding shares of Yco. 12. ... At current rates, the interest is estimated to be equal to XXXXXXXXXX % per annum compounded monthly. 23. ...
Ruling

2008 Ruling 2008-0264671R3 - Entity Classification

The Shareholder owned approximately XXXXXXXXXX % of the issued and outstanding shares of Parent prior to XXXXXXXXXX. ... XXXXXXXXXX Holdco owns approximately XXXXXXXXXX % of the issued and outstanding shares of Newco. 5. ... Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling

2008 Ruling 2008-0281941R3 - Donation of flow-through shares

Pursuant to the agency agreement, the Agent will receive from the Resource Company a cash commission of XXXXXXXXXX % of the gross proceeds from sales of shares under the offering, plus warrants entitling the Agent to acquire such number of common shares equal to XXXXXXXXXX % of the shares sold. ... ACO is a participant in the selling group and will receive from the Agent, out of the commission payable by the Resource Company to the Agent, a commission equal to XXXXXXXXXX % of the gross proceeds of the shares that it sells. ACO will also be entitled to receive out of the Agent's warrants, warrants representing XXXXXXXXXX % of the shares sold. 12) The Donors will open a non-discretionary brokerage account with ACO and will deposit sufficient cash to pay the anticipated subscription price for the Shares. ...

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