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Ruling
30 November 1997 Ruling 9809273 - BUTTERFLY REORGANIZATION
To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayers or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ... The issued and outstanding shares of each class of shares of Investco are owned as follows: Shareholder # of Shares Class The Trust XXXXXXXXXX Class A Preferred XXXXXXXXXX Class B Preferred A XXXXXXXXXX Common XXXXXXXXXX Class A Preferred XXXXXXXXXX Class C Preferred B XXXXXXXXXX Common XXXXXXXXXX Class A Preferred XXXXXXXXXX Class C Preferred C XXXXXXXXXX Common XXXXXXXXXX Class A Preferred XXXXXXXXXX Class C Preferred 8. ...
Ruling
30 November 1997 Ruling 9804043 - TRIANGULAR AMALGAMATION
The v-day value and the amount to retire each XXXXXXXXXX is as follows: Cdn $ XXXXXXXXXX V-day values XXXXXXXXXX XXXXXXXXXX Retirement amount (estimated) XXXXXXXXXX XXXXXXXXXX The retirement amount of the XXXXXXXXXX will not be less than the fair market value, on valuation day, of the XXXXXXXXXX issued. 33. ... The v-day value and the amount to retire each XXXXXXXXXX is as follows: Cdn $ XXXXXXXXXX V-day values XXXXXXXXXX XXXXXXXXXX Retirement amount (estimated) XXXXXXXXXX XXXXXXXXXX The retirement amount of the XXXXXXXXXX will not be less than the fair market value, on valuation day, of the XXXXXXXXXX issued. 35. ...
Technical Interpretation - Internal
17 August 1995 Internal T.I. 9518307 - INDIANS - GUIDELINE 4
In this respect, La Forest, J. stated that: "... one must guard against ascribing an overly broad purpose to ss. 87 and 89. ... " LaForest, J. concluded that: "... Indians, when engaging in the cut and thrust of business dealings in the commercial mainstream are under no illusions that they can expect to compete from a position of privilege with respect to their fellow Canadians. ...
Ruling
2003 Ruling 2002-0178933 - AMENDED PLAN
If Shares rank at the XXXXXXXXXX percentile (i.e. compared to all corporations in the XXXXXXXXXX), the Eligible Employee will be paid an amount equal to XXXXXXXXXX % of the target cash award set by the Committee in respect of that Performance Period. At the XXXXXXXXXX percentile rank, the Eligible Employee will be paid an amount equal to XXXXXXXXXX % of the target cash award set by the Committee and at or above the XXXXXXXXXX percentile rank, the Eligible Employee will be paid an amount (i.e. the maximum) equal to XXXXXXXXXX% of the target cash award set by the Committee in respect of that Performance Period. ...
Ruling
2003 Ruling 2002-0166673 - Reorganization of foreign affiliates
As a result of the USCo acquisition, Canco acquired an additional indirect XXXXXXXXXX % interest in the JV. ... In addition to the XXXXXXXXXX % JV interest, FA1 owns XXXXXXXXXX. XXXXXXXXXX. ...
Ruling
2004 Ruling 2003-0051351R3 - ATR - Salary Deferral Arrangement
Subject to paragraph 28 below, on the Maturity Date of the PSUs that are described in paragraphs 16 and 22 above, the Corporation will pay to a Plan Participant an amount (hereafter referred to as the "Amount Payable") equal to the following equation: Amount Payable = Number of mature PSUs X Closing Price X Performance Multiplier X Pro Ration Factor Where: "Closing Price" equals the Market Value of a Share at the Maturity Date; "Performance Multiplier" equals the number not less than zero (0) and not greater than 2, determined in accordance with paragraph 29 below and subject to paragraph 28 below; and "Pro Ration Factor" equals 1, unless determined to be a number less than 1 pursuant to paragraph 28 below. 25. ... (c) Between XXXXXXXXXX, the Performance Multiplier will be calculated in accordance with the following equation: Performance Multiplier = [XXXXXXXXXX x Peer Ranking]- 1 However, if; (i) the calculation yields a result less than XXXXXXXXXX the Performance Multiplier will be deemed to be zero (0) and all rights with respect to any mature PSUs credited to the PSU Account of the Plan Participant will be terminated and the Plan Participant will receive no payment of any kind with respect thereto; and (ii) the calculation yields a result that is greater than XXXXXXXXXX, the Performance Multiplier will be deemed to be XXXXXXXXXX. 30. ...
Ruling
2003 Ruling 2003-0051283 - XXXXXXXXXX ATR
Before it was dissolved as described in paragraph 15 below, Cansub#2 owned a XXXXXXXXXX % interest in the partnership and Cansub#3, a subsidiary wholly-owned corporation of Cansub#2, owned a XXXXXXXXXX% interest. 7. ... On XXXXXXXXXX, Cansub#3 declared and paid a dividend in kind to Cansub#2 consisting of its undivided XXXXXXXXXX % interest in the Cansub#1 Class C Preferred shares. 17. ...
Ruling
2004 Ruling 2004-0069751R3 - Buy, Bump and Sell Transactions
As part of the development process that has occurred in the vicinity of the Land, adjacent third party land owners (the "Third Party Owners"), who are unrelated to each of Farmco1 and Farmco2 and each such corporation's shareholders, commenced the process of creation of a NASP affecting their own lands, and in that process, the Third Party Owners included approximately XXXXXXXXXX % of the Land in the NASP. ... As consideration for the transfer of the Land to DeveloperCo, PurchaseCo will receive the $XXXXXXXXXX as follows: cash on closing of $XXXXXXXXXX and a vendor take-back mortgage in the amount of $XXXXXXXXXX, plus interest at a rate of prime plus XXXXXXXXXX %. ...
Ruling
2004 Ruling 2004-0101501R3 - Deferred Share Units
However, if the Participating Employer determines for whatever reason at any time to pay the Participant a Lump Sum Payment, then effective as at the Lump Sum Payment Date the Participant will be entitled to: (i) XXXXXXXXXX % of a pro rata number of the Regular Units recorded in the Participant's Record as at the Lump Sum Payment Date; plus (ii) XXXXXXXXXX % of a pro rata number of the Performance Units recorded in the Participant's Record as at the Lump Sum Payment Date, based on the portion of the Entitlement Period that has been completed as at the Lump Sum Payment Date and all other Units recorded in the Participant's Record will be forfeited as at the Lump Sum Payment Date. ...
Ruling
2004 Ruling 2004-0089721R3 - Exploration/new mine- CEE?
" means XXXXXXXXXX (which holds approximately XXXXXXXXXX % of the shares of X Co.), "X Co. ... XXXXXXX XXXXXX XXXXXX XXXXXX Headframe & Hoist XXXXXXX XXXXXX XXXXXX XXXXXX Underground Excavation XXXXXXX XXXXXX XXXXXX XXXXXX Exploration Drilling XXXXXXX XXXXXX XXXXXX XXXXXX Metallurgical Test Work XXXXXXX XXXXXX XXXXXX XXXXXX Surface Infrastructure XXXXXXX XXXXXX XXXXXX XXXXXX Environment management XXXXXXX XXXXXX XXXXXX XXXXXX Freight XXXXXXX XXXXXX XXXXXX XXXXXX Indirect Costs XXXXXXX XXXXXX XXXXXX XXXXXX TOTAL XXXXXXX XXXXXX XXXXXX XXXXXX There is a possibility that the proposed shaft and drifts will be used for production purposes, if and when, X Co. brings the property into production. ...