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Assureur est une filiale à XXXXXXXXXX % de Société qui est une compagnie constituée par XXXXXXXXXX. ...

The XXXXXXXXXX shares will carry the following rights and restrictions: par value of $ XXXXXXXXXX per share; dividends will be non-cumulative with a stated dividend rate attached to the share class; will not have voting rights, except in respect of matters which affect the rights attributable to the XXXXXXXXXX shares; redeemable solely at ACO's discretion for an amount equal to the shares' par value plus any declared, but unpaid dividends; are equity shares as defined in the XXXXXXXXXX and will share pari passu upon liquidation or wind up of ACO with the XXXXXXXXXX shares; and dividends will be payable in cash or as stock, at the option of ACO. 11. ...

ACO reported a gain of $XXXXXXXXXX in XXXXXXXXXX from the disposition of its XXXXXXXXXX % interest in XXXXXXXXXX ("FCO") by way of a share redemption. ...

Yours truly, for Director Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch 6... ...

The second sentence of paragraph 5 k) should read as follows: k) (...). ...

The insurer involved is the XXXXXXXXXX (the " Insurer"). 4. ...

In Australia, Canco carries on its XXXXXXXXXX business through a branch (the " Branch"). ...

(a) The terms of settlement in respect of damages for personal injury, provide, among other matters, for payment to the Claimant of the following: i) The lump sum of $ XXXXXXXXXX together with costs in the sum of XXXXXXXXXX; and ii) Guaranteed lump sum payments of. ...

2020 Ruling 2020-0850081R3- Retiring Allowance Unedited CRA Tags 6(3); 248(1); 56(1)(a); 212(1)(j.1) * Principal Issues: What is the character of periodic amounts paid to an employee under an employment agreement who was terminated pursuant to the terms of the employment agreement? ...

2020 Ruling 2020-0847041R3- Payment of damages Unedited CRA Tags 248(1)- definition of "retiring allowance" * Principal Issues: What is the tax character of a payment of damages payable to a terminated employee resulting from a wrongful dismissal suit? ...