Search - 哈尔滨到北京 公里数

There is no person that beneficially owns more than XXXXXXXXXX % of the shares of Parent. 3. ... The non-capital losses of Parent carried forward from prior years are as follows: Year of origin Non-Capital Loss XXXXXXXXXX XXXXXXXXXX * estimate 5. ... The holders of preferred shares will be entitled to cumulative dividends, calculated daily by reference to the redemption/retraction price of the preferred shares at a rate equal to the sum of the interest rate on the Lossco Loan plus XXXXXXXXXX %. ...

The Units of the CCF do not have any voting rights (save the right, on written notice signed by Unitholders holding XXXXXXXXXX % of the Units, to require the manager to resign). ... The CCF will not purchase more than XXXXXXXXXX % of the outstanding shares of any one issuer and will monitor its portfolio to ensure that its holdings do not exceed this XXXXXXXXXX % threshold. 19. ...

2007 Ruling 2006-0191631R3- XXXXXXXXXX Unedited CRA Tags 98(6) 132.2 Principal Issues: Rulings confirm tax consequences of a REIT reorganization in order to simplify the structure of the MFT...ie. conversion of a general partnership to a limited partnership & elimination of currently existing layers of corporations through amalgamation and transfers of assets using various rollover to achieve simplification. ... Provided that, at the time of Asset Transfer #2, Amalco #2 is a mutual fund corporation, the Fund is a mutual fund trust, the property transferred has a fair market value of at least 90% of the fair market value of all property owned by Amalco # 2 at that time and provided that joint elections are filed in prescribed form and within the time set out in to paragraph (c) of the definition of qualifying exchange in subsection 132.2(2), the transactions described in Paragraph IV.20 and IV.21 above will constitute a "qualifying exchange" such that provisions of subsections 132.2(1) will apply to: (a) the transfer of the LP Units from Amalco #2 to the Fund described in Paragraph IV.20; and (b) the redemption of the Class A and Class B shares by Amalco #2 described in Paragraph IV.21. ... XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

The dividend rate will be equal to the rate of interest that will be charged on the Aco Demand Loan plus XXXXXXXXXX % as determined at the time of the Proposed Transactions; and (c) the shares will be redeemable at any time at the option of the holder or NewcoA for an amount equal to the aggregate redemption amount and any unpaid dividends, by NewcoA: (i) paying cash equal to the aggregate redemption amount and any unpaid dividends; (ii) assigning all or a portion of the Topco Demand LoanA with a principal amount and fair market value equal to the aggregate redemption amount of the shares so redeemed and paying cash equal to any unpaid dividends; or (iii) setting off amounts owing under the Aco Demand Loan having a principal amount and fair market value equal to the aggregate redemption amount of the NewcoA Preferred Shares so redeemed in circumstances where NewcoA has become the holder of the Aco Demand Loan, and paying cash equal to any unpaid dividends. ... The dividend rate will be equal to the rate of interest that will be charged on the Bco Demand Loan plus XXXXXXXXXX % as determined at the time of the Proposed Transactions. ... The dividend rate will be equal to the rate of interest that will be charged on the Cco Demand Loan plus XXXXXXXXXX % as determined at the time of the Proposed Transactions. ...

July 4, 2003 International Tax Directorate Resource Industries Section Policies & Publications Unit A.A. ... In our view, this latter point highlights the difference between the "dependent on the use of or production from property" test contained in paragraph 12(1)(g) of the Act (which the Courts have traditionally interpreted as a "continuous / on-going" basis test consistent with the predecessor to that paragraph which expressly provided for the "continuous" nature of this test), and the test contained in paragraph 212(1)(e) of the Act. The latter test only requires that "the consideration is...dependent on, or computed by reference to, the amount of timber cut or taken", disregarding whether the timber is cut or taken on a "one-time" basis or "continuous / on-going" basis. ...

The aggregate stated capital, paid-up capital and aggregate adjusted cost base to each shareholder of each class of issued and outstanding shares of DC are as follows: Shareholder Class # of Shares Stated Capital/PUC ACB Parent Class A- Series 1 XXXXXXXX XXXXXXXX XXXXXXXXX Class B XXXXXXXX XXXXXXXXX XXXXXXXXX Class C XXXXXXXX XXXXXXXXX XXXXXXXXX TC 1 Class A- Series 2 XXXXXXXX XXXXXXXXX XXXXXXXXX Class B XXXXXXXX XXXXXXXXX XXXXXXXXX Class C XXXXXXXX XXXXXXXXX XXXXXXXXX TC 2 Class A- Series 2 XXXXXXXX XXXXXXXXX XXXXXXXXX Class B XXXXXXXX XXXXXXXXX XXXXXXXXX Class C XXXXXXXX XXXXXXXXX XXXXXXXXX Each of TC 1 and TC 2 acquired its XXXXXXXXXX Class B shares and XXXXXXXXXX Class C shares of DC on XXXXXXXXXX for cash consideration of $XXXXXXXXXX per share, respectively. ... The aggregate stated capital, paid-up capital and aggregate adjusted cost base to each shareholder, of each class of issued and outstanding shares of TC 1 are as follows: Shareholder Class # of Shares Stated Capital/PUC/ACB Sibling 1 Class A XXXXXXXXXX XXXXXXXXXX Class B XXXXXXXXXX XXXXXXXXXX Class A Preferred XXXXXXXXXX XXXXXXXXXX Sibling 1 Trust Class B XXXXXXXXXX XXXXXXXXXX 5. ... The aggregate stated capital, paid-up capital and redemption amount (where applicable) and aggregate adjusted cost base to each shareholder, of each class of issued and outstanding shares of TC 2 are as follows: Shareholder Class # of Shares Stated Capital/PUC/ACB Sibling 2 Class A XXXXXXXXXX XXXXXXXXXX Class B XXXXXXXXXX XXXXXXXXXX Class A Preferred XXXXXXXXXX XXXXXXXXXX Sibling 2 Trust Class B XXXXXXXXXX XXXXXXXXXX 7. ...

Propertyco also owns a XXXXXXXXXX % co-ownership interest (the "Interest") in XXXXXXXXXX lands, facilities and chattels and related inventories, accounts receivable and deposits (collectively, the "Facility") that Propertyco and an arm's length third party (XXXXXXXXXX, or the "Co-owner") hold as equal tenants-in-common. ... The Preference Shares will be non-voting, entitled to dividends as and when declared by the directors, redeemable and retractable at their redemption amount which will be equal to the fair market value of the consideration for which they are issued (in aggregate, the "Preference Share Redemption Amount"), bear a quarterly non-cumulative dividend equal to XXXXXXXXXX % of the Preference Share Redemption Amount and will rank ahead of the common shares as to the payment of dividends and, on a liquidation or winding-up, of the redemption amount. ... The Voting Shares will carry one vote per share, will be redeemable and retractable for their redemption amount of $XXXXXXXXXX per share and (if not already redeemed) will be entitled to receive the redemption amount on a winding-up or liquidation of New Holdco, will bear a non-cumulative annual dividend of XXXXXXXXXX % of the redemption amount, and will rank ahead of the New Preference Shares and the common shares as to the payment of dividends and, on a liquidation or winding-up, of the redemption amount. ...

Not if before the end of the taxation year in which the production expenditures are made, income in respect of the film exceeding XXXXXXXXXX % of such production expenses is included in computing the Production Partnership's income for that year. 2. ... The general partner of the Production Partnership will own a 0.01% interest; b) once the substription price for Class B Units has been paid in cash, subject to the exemption described below in paragraph c), 99.99% of the profits and losses of the Production Partnership will be allocated rateably between the holders of the Class A Units and the Class B Units, based upon the amount of their partnership capital at the end of the relevant fiscal period (i.e. approximately XXXXXXXXXX % of the 99.99% share of the Production Partnership's profits and losses for the MLP, and approximately XXXXXXXXXX % of the 99.99% share for THC). ...

None of Aco, Bco or Newco is or will be at the time of the Proposed Transactions a specified financial institution. 45.1 For all purposes of the Act, including filing its return of income or any prescribed forms, Aco will apply subsections 13 and 20 (and any regulations made for the purpose of paragraph 20(1)(a)) on the basis that the capital cost to Aco of the Trademarks acquired from Newco on the winding-up of Newco as described in Paragraph 36 will be deemed by subparagraph 13(7)(e)(ii) to be equal to the capital cost of the Trademarks to Newco before the winding-up for the same purposes, being $XXXXXXXXXX. 45.2 For all purposes of the Act, including filing its return of income or any prescribed forms, Bco will apply subsections 13 and 20 (and any regulations made for the purpose of paragraph 20(1)(a)), on the basis that the capital cost to Bco of the Trademarks acquired from Aco as described in Paragraph 39 will be deemed by subparagraph 13(7)(e)(ii) to be $XXXXXXXXXX, being equal to the aggregate of the $XXXXXXXXXX capital cost of the Trademarks to Aco, as determined under paragraph 13(7)(e), and ½ of the amount of the $XXXXXXXXXX capital gain realized by Aco on the transfer. ... The provisions of subparagraph 13(7)(e)(ii) will apply to the transfer by Bco of the Trademarks to Newco described in Paragraph 27, such that subject to subsection 70(13), for the purposes of paragraphs 8(1)(j) and (p), section 13, section 20 and any regulations made for the purpose of paragraph 20(1)(a), the capital cost of the Trademarks to Newco will be $XXXXXXXXXX, being equal to the total of the XXXXXXXXXX capital cost of the Trademarks to Bco immediately before the transfer and ½ of the amount of the $XXXXXXXXXX capital gain realized by Bco on the transfer. ... The provisions of subparagraph 13(7)(e)(ii) will apply to the transfer by Aco of the Trademarks to Bco described in Paragraph 39, such that subject to subsection 70(13), for the purposes of paragraphs 8(1)(j) and (p), section 13, section 20 and any regulations made for the purpose of paragraph 20(1)(a), the capital cost of the Trademarks to Bco will be $XXXXXXXXXX, being equal to the aggregate of the $XXXXXXXXXX capital cost of the Trademarks to Aco and ½ of the amount of the $XXXXXXXXXX capital gain realized by Aco on the transfer. ...

Des 90 actions détenues par monsieur et madame Gasner, étaient des actions comportant les caractéristiques des actions ordinaires alors que 80 étaient des actions privilégiées rachetables pour 1,00 $ l'action et qui donnaient droit à un dividende fixe, préférentiel et cumulatif de 10% sans plus. ... "Lorsqu' ils ont prétendu mettre fin à leur ontrôle de l'intimée en lui faisant émettre 80 actions privilégiées, pour la somme de 80 $, aux actionnaires minoritaires qui détenaient 10 pour cent des actions ordinaires, les Gasner, les Wingold ont retenu un droit capital qu'ils ont par la suite cédé à Validor, celui de liquider la société intimée si jamais il était dans leur intérêt de le faire. ... Le contrôle, au sens véritable du terme, n'a pas été abandonné par les Wingold (et leur successeur, Validor) en 1960, par suite de l'émission au groupe Gasner d'actions privilégiées pour la somme de 80 $. ...