Search - 司法拍卖网 人民法院

The Lossco Loan #1 will bear simple interest at a rate equal to the XXXXXXXXXX prime rate of interest plus XXXXXXXXXX % per annum which is not greater than the rate that Profitco would pay to an arm's length Canadian financial institution to borrow an equivalent amount on equivalent repayment terms. 13. ... The Lossco Loan #2 will bear simple interest at a rate equal to the XXXXXXXXXX prime rate of interest plus XXXXXXXXXX % per annum which is not greater than the rate that Profitco would pay to an arm's length Canadian financial institution to borrow an equivalent amount on equivalent repayment terms. 17. ... The Lossco Loan #3 will bear simple interest at a rate equal to the XXXXXXXXXX prime rate of interest plus XXXXXXXXXX % per annum which is not greater than the rate that Profitco would pay to an arm's length Canadian financial institution to borrow an equivalent amount on equivalent repayment terms. 21. ...

To the best of Buyerco's knowledge, the XXXXXXXXXX largest common shareholders of Buyerco immediately before XXXXXXXXXX were: Shareholder % XXXXXXXXXX In XXXXXXXXXX acquired ownership of the shares of the capital stock of Buyerco owned by XXXXXXXXXX. XXXXXXXXXX was the registered owner of approximately XXXXXXXXXX % of the shares of the capital stock of Buyerco and held these shares for various investors who, through brokerage firms or other investment firms, were the beneficial owners of the said shares. 3. ... To the best of Target's knowledge, the XXXXXXXXXX largest common shareholders of Target immediately before XXXXXXXXXX were: Shareholder % BuyerSubco III XXXXXXXXXX XXXXXXXXXX To the best of Target's knowledge, the XXXXXXXXXX largest common shareholders of Target XXXXXXXXXX: Shareholder % XXXXXXXXXX XXXXXXXXXX The above shareholding information was obtained from the non-objecting beneficial owners ("NOBO") lists of Target shares. ...

A CO holds: (i) XXXXXXXXXX % of the shares of F CO, which indirectly holds interests in the XXXXXXXXXX project in XXXXXXXXXX and in XXXXXXXXXX; (ii) XXXXXXXXXX % of the shares of XXXXXXXXXX, a corporation established under the laws of XXXXXXXXXX, which indirectly holds interests in certain XXXXXXXXXX properties in XXXXXXXXXX; and (iii) XXXXXXXXXX % of the shares of XXXXXXXXXX, a corporation established under the laws of XXXXXXXXXX which indirectly holds interests in certain XXXXXXXXXX properties in XXXXXXXXXX (including the XXXXXXXXXX project). 4. ... As at XXXXXXXXXX, XXXXXXXXXX was approximately XXXXXXXXXX % owned by DC through B CO. 4.2 In XXXXXXXXXX, XXXXXXXXXX completed a reverse take over with XXXXXXXXXX. ... DC currently holds through B CO an approximate XXXXXXXXXX % interest in the common shares of XXXXXXXXXX. ...

BCO is a holding company that owns XXXXXXXXXX % of the shares of XXXXXXXXXX which carries on XXXXXXXXXX. 16. ... This $XXXXXXXXXX amount represented XXXXXXXXXX % of the estimated income of CCO to XXXXXXXXXX reportable proportionately (XXXXXXXXXX %) for XXXXXXXXXX tax purposes by the XXXXXXXXXX beneficiary. ... (f) Trust 1 distributed XXXXXXXXXX % of the dividend received from CCO to the Beneficiary resident XXXXXXXXXX and XXXXXXXXXX% to XXXXXXXXXX new corporations incorporated in Paragraph 19(b) that qualify as beneficiaries of Trust 1. ...

The relative sizes of the United States and Canadian business segments operated by the members of US Group and the Canco Group, measured in terms of revenue and assets for financial statement purposes, are approximately as follows: Based on XXXXXXXXXX financial information F/X rate = XXXXXXXXXX Canada U.S. Canada as a % (millions in USD) (millions in USD) of Total Total Operations Revenue XXXXX XXXXX XXXXX Assets XXXXX XXXXX XXXXX XXXXXXXXXX Revenue XXXXX XXXXX XXXXX Assets XXXXX XXXXX XXXXX XXXXXXXXXX Revenue XXXXX XXXXX XXXXX Assets XXXXX XXXXX XXXXX XXXXXXXXXX Revenue XXXXX XXXXX XXXXX Assets XXXXX XXXXX XXXXX XXXXXXXXXX Revenue XXXXX XXXXX XXXXX Assets XXXXX XXXXX XXXXX XXXXXXXXXX Revenue XXXXX XXXXX XXXXX Assets XXXXX XXXXX XXXXX The figures set out in the chart are based on XXXXXXXXXX financial information but continue to represent reasonable approximations of the assets and the annual revenues relating to the various business segments. ... Yours truly, for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Une fois ses études complétées, la somme payable annuellement sera de XXXXXXXXXX $ et ce, tant et aussi longtemps que les fonds seront suffisants. ... Les actions de catégorie « B » sont non votantes, non participantes et donnent droit à un dividende XXXXXXXXXX et non cumulatif au taux de XXXXXXXXXX de XXXXXXXXXX % de la valeur de rachat. ... Les actions de catégorie « C » sont non votantes, non participantes et donnent droit à un dividende XXXXXXXXXX et non cumulatif au taux de XXXXXXXXXX de XXXXXXXXXX % de la valeur de rachat. ...

The Target directors' circular dated XXXXXXXXXX provided that "XXXXXXXXXX " 11. ... The proportion of value that the entire XXXXXXXXXX represents of Amalco is generally estimated at XXXXXXXXXX %. 13. ... The proportion of value that Amalco represents of Pubco I is generally estimated at XXXXXXXXXX %. 19. ...

The transfers from Foreign Pubco to Foreign Holdco 1, and further down the corporate chain, described in (c)(ii), will be either for cash, shares and / or share premium or by way of a capital contribution. ... The aggregate FMV, immediately before the transfer of property by Canadian DC to Canadian TC described in Paragraph 55, of the units of Foreign DC owned by Forco 2 will be equal to or approximate the amount determined by the formula: (A × B/C) + D as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1) on the assumption that Forco 2 is the participant, Canadian DC is the distributing corporation and Foreign DC is the acquiror. ... The aggregate FMV, immediately before the transfer of property by Foreign DC to Foreign TC described in Paragraph 67, of the units of New LLC owned by Foreign Pubco will be equal to or approximate the amount determined by the formula: (A × B/C) + D as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1) on the assumption that Foreign Pubco is the participant, Foreign DC is the distributing corporation and New LLC is the acquiror. ...

To the knowledge of the directors and senior officers of DC, as of the date hereof, no person or related group of persons beneficially owns, directly or indirectly, XXXXXXXXXX % or more of the DC Common Shares. ... On XXXXXXXXXX, DC acquired XXXXXXXXXX approximately XXXXXXXXXX % of Target Shares. 4.2. ... For the fiscal period ended XXXXXXXXXX, the revenue from DC's XXXXXXXXXX business represented approximately XXXXXXXXXX % of DC's total revenues, while the revenue from DC's XXXXXXXXXX business represented approximately XXXXXXXXXX % of DC's total revenues. ...

It is anticipated that the principal amount of the DC Subco Promissory Note, if none of the real properties are sold, will be less than $XXXXXXXXXX, being less than XXXXXXXXXX % of the value of DC's assets. ... H wishes to cash out that proportion of his share equity which represents XXXXXXXXXX % of all the share equity of DC (i.e. the Cash Call Proportion), the consideration to be paid to Mr. ... H shall be entitled to the benefit of the Cash Call Proportion of any capital or non-capital losses available to DC and in particular the XXXXXXXXXX loss carry forwards described in paragraph 9), (ii) the addition to DC's RDTOH arising as a result of the disposition of such XXXXXXXXXX Shares, (iii) XXXXXXXXXX % of the RDTOH prior to the disposition of XXXXXXXXXX Shares to satisfy the Cash Call and (iv) XXXXXXXXXX % of DC's other assets, less (v) XXXXXXXXXX % of DC's liabilities (other than the tax liabilities contemplated in (i) above). ...