Search - 司法拍卖网 人民法院

The issued share capital of XXXXXXXXXX is held as follows: Shareholder # common # special Name shares shares XXXXXXXXXX All of the shares of XXXXXXXXXX represent capital property to the shareholders. ...

The tax attributes of the Opco-A Shares and Opco-B Shares held by the Estate immediately after Individual X’s death were as follows: Number Class ACB ($) PUC ($) FMV($) XXXXX Class A Common XXXXX XXXXX XXXXX Shares of Opco-A XXXXX Class B Preference XXXXX XXXXX XXXXX Shares of Opco-A XXXXX Class C Preference XXXXX XXXXX XXXXX Shares of Opco-A XXXXX Class H Special XXXXX XXXXX XXXXX Shares of Opco-A XXXXX Class A Common XXXXX XXXXX XXXXX Shares of Opco-B XXXXX Class D Preference XXXXX XXXXX XXXXX Shares of Opco-B XXXXX Class E Preference XXXXX XXXXX XXXXX Shares of Opco-B XXXXX Class H Special XXXXX XXXXX XXXXX Shares of Opco-B 32. ...

The Individual holds XXXXXXXXXX % of C Co's issued shares with XXXXXXXXXX % of the votes. ...

Trust One holds a XXXXXXXXXX % interest in the Limited Partnership. 4. ... The initial required Cumulative Distributable Income Increase of the Fund per Unit has been set as XXXXXXXXXX %. ... The Time Based Vesting Condition is applicable to XXXXXXXXXX % of the RUs credited to a Participant's Account in accordance with 11(n) and 12(c) above. ...

The beneficiaries under Newtrust are the same as under the Estate except that Grandchild #1 will only have a XXXXXXXXXX % interest in Newtrust and the other XXXXXXXXXX % interest will be held by a new family trust (Family Trust) which will be created for the benefit of Grandchild #1, his children and grandchildren only if Grandchild #1 survives the Daughter. ... The terms of Newtrust will be as follows: (a) The Daughter will be entitled to receive all of the income of Newtrust during her lifetime; and (b) Upon the death of the Daughter, Newtrust property will be divided into equal shares ("Share #1" and "Share #2", respectively) and paid as follows: i) If Grandchild #1 is alive at the death of the Daughter, XXXXXXXXXX% of Share #1 will be paid to Grandchild #1 and XXXXXXXXXX % of Share #1 will be paid to the trustees of Family Trust (described below); ii) If Grandchild #1 is not alive at the death the Daughter, but there are one or more children of Grandchild #1 alive at the death of the Daughter, Share #1 will be paid equally to the children of Grandchild #1; iii) If none of Grandchild #1, or his or her children are alive at the death of the Daughter, but Grandchild #2 is alive at the death of the Daughter, Share #1 will be paid to Grandchild #2; iv) If none of Grandchild #1, any child of Grandchild #1 or Grandchild #2 is alive at the death of the Daughter, Share #1 will be paid equally to the children of Grandchild #2; v) If none of Grandchild #1, his or her children, Grandchild #2 or his or her children are alive at the death of the Daughter, Share #1 will be paid to the Foundation; vi) If Grandchild #2 is alive at the death of the Daughter, Share #2 will be paid to Grandchild #2; vii) If Grandchild #2 is not alive at the death of the Daughter, Share #2 will be paid equally to his or her children; viii) If none of Grandchild #2, or his or her children are alive at the death of the Daughter, but Grandchild #1 is alive at the death of the Daughter, XXXXXXXXXX% of Share #2 will be paid to Grandchild #1 and XXXXXXXXXX% of Share #2 will be paid to the trustees of Family Trust; ix) If none of Grandchild #2, his or her children or Grandchild #1 is alive at the death of the Daughter, Share # 2 will be paid equally to the children of Grandchild #1; and x) If none of Grandchild #1, his or her children, Grandchild #2, or his or her children is alive at the death of the Daughter, Share #2 will be paid to the Foundation. 15. ... The death benefit will be an amount not less than 60.46 % of the total FMV of the securities and class B Holdcol or Holdco2 shares received by the Grandchild as capital encroachments from the Estate. ...

Definitions (a) "CRA" means Canada Revenue Agency; (b) "Head Lease" is the lease agreement entered into between XXXXXXXXXX and XXXXXXXXXX with respect to the XXXXXXXXXX Lands described in more detail in Paragraphs 8 to 11; (c) "XXXXXXXXXX ", a corporation described in Paragraph 7, means XXXXXXXXXX; (d) "XXXXXXXXXX ", a corporation described in Paragraph 1, means XXXXXXXXXX; (e) "Paragraph" means a numbered paragraph in this letter; (f) XXXXXXXXXX; (g) "XXXXXXXXXX Lands" means the fee simple interest in land owned by XXXXXXXXXX and acquired as described in Paragraph 9 and includes the XXXXXXXXXX Property and the Subleased Property; (h) "XXXXXXXXXX Property" means the land that is subject to the Head Lease and is the land on which XXXXXXXXXX but excludes the Subleased Property; (i) "Subleased Property" means the land that is subject to the Head Lease and which is subject to Subleases between XXXXXXXXXX and the Sublessees; (j) "Subleases" are those long-term sub-leases of land described in Paragraphs 2 to 4 between XXXXXXXXXX and arm's length parties; (k) "Sublessee(s)" means those persons that have entered into Subleases with XXXXXXXXXX, and includes XXXXXXXXXX ("Sublessee #1") and XXXXXXXXXX ("Sublessee #2"). ... Approximately XXXXXXXXXX % of the Sublessees hold their Subleased Property for personal purposes. ... Sublessee # 1 and Sublessee #2 will not receive a promissory note from XXXXXXXXXX as they have not entered into XXXXXXXXXX-year leases with XXXXXXXXXX as described in Paragraph 6. 15. ...

This left Shareholders 1 & 2 as the sole shareholders of Distributor. ... All of the individuals (Shareholders 1 & 2) are resident in Canada for purposes of the Act. ... The subsection 85(1) election referred to herein will exclude any cash, accounts receivable, NISA Fund # 1, and prepaid expenses. 51. ...

XXXXXXXXXX 2020-087496 XXXXXXXXXX, 2021 RE: Advance Income Tax Ruling – 55(3)(a) XXXXXXXXXX This is in reply to your letter dated XXXXXXXXXX, in which you requested an advance income tax ruling on behalf of the above-noted taxpayer. ... Class A preferred shares – (i) non-voting; (ii) redeemable/retractable for $XXXXXXXXXX/share; (iii) entitled to non-cumulative dividends at the discretion of the Board of Directors; and (iv) on liquidation, dissolution or wind-up, ranks in priority to Class B preferred shares and Class V special shares and all classes of common shares; d. ... Class V special shares – (i) XXXXXXXXXX vote per share; (ii) redeemable/retractable for $XXXXXXXXXX per share; (iii) not entitled to dividends; and (iv) on liquidation, dissolution or wind-up, ranks behind Class A and Class B preferred shares but has priority over all classes of common shares. 21. ...

LPco formerly held one Class B limited partner unit in each of the LP Purchasers, Master LP and Holding LP before the transactions described in paragraphs 13 and 20; "LPs Purchasers" means LP I, LP II, LP III, LP V, LP VI, LP VII and LP VIII; "LPs Purchasers LP Units" means the Class A limited partner units issued by each of the LP Purchasers to Trust I, as described in paragraph 16; "Master LP" means XXXXXXXXXX, a limited partnership with a fiscal period end of XXXXXXXXXX, formed under the laws of the province of XXXXXXXXXX to acquire, invest in and XXXXXXXXXX; "Master LP Units" means the Class A limited partner units of Master LP that were issued to Trust I, as described in paragraph 21; "XXXXXXXXXX Interest Partnership" means Parent's XXXXXXXXXX % XXXXXXXXXX interest in the XXXXXXXXXX before the transfer to Holding LP described in paragraph 25; "net capital loss" has the meaning assigned by subsection 111(8); "Net Realized Capital Gains" means, as defined in section 1.1 of the Trust I Contract of Trust, the amount for any period, if any, by which the capital gains of Trust I for the period exceeds the aggregate of the amount of any capital losses of Trust I for the period determined in accordance with the Act; "New Parent" means the resulting corporation from the amalgamation of Parent and Subco, as described in paragraph 39; "New XXXXXXXXXX " means XXXXXXXXXX trust that was established on XXXXXXXXXX, with a contribution of $XXXXXXXXXX by XXXXXXXXXX. ... "New Trust V" means a trust established under the laws of XXXXXXXXXX for the exclusive benefit of Trust I XXXXXXXXXX; "New Trust VI" means a trust established under the laws of XXXXXXXXXX for the exclusive benefit of Trust I XXXXXXXXXX; "New Trust VII" means a trust established under the laws of XXXXXXXXXX for the exclusive benefit of Trust I XXXXXXXXXX; "New Trust VIII" means a trust established under the laws of XXXXXXXXXX for the exclusive benefit of Trust I XXXXXXXXXX; XXXXXXXXXX; "Parent" means XXXXXXXXXX corporation continued under the laws of XXXXXXXXXX; "Parent's Partnerships" means the following partnerships in which Parent has an interest: XXXXXXXXXX "Parent's Partnership Units" mean the following partnership units of the Parent's Partnerships: XXXXXXXXXX XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; "XXXXXXXXXX GP" means XXXXXXXXXX, a corporation all shares of which are owned by New XXXXXXXXXX; "XXXXXXXXXX LP" means XXXXXXXXXX, a limited partnership created on XXXXXXXXXX with New XXXXXXXXXX and XXXXXXXXXX GP as the initial limited partner and general partner, respectively; "XXXXXXXXXX LP Units" means the Class A limited partner units of XXXXXXXXXX LP that were initially issued to Holding LP and Master LP, as described in paragraph 28; "XXXXXXXXXX " has the meaning assigned by subsection 248(1); "XXXXXXXXXX " has the meaning assigned by subsection 248(1); "Sisterco" means XXXXXXXXXX, a corporation incorporated under the laws of XXXXXXXXXX. ... Yours truly, for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

The Class C shares are non-voting and entitled to discretionary non-cumulative dividends of up to XXXXXXXXXX % of the redemption amount annually. ... The Class F shares are non-voting and entitled to discretionary non-cumulative dividends of up to XXXXXXXXXX % of the redemption amount annually. ... DC owns XXXXXXXXXX % of JV1 and XXXXXXXXXX % of JV2. Gains, profits and losses are reported by each of the JV participants on the basis of their proportionate ownership in the JV. ...