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Ruling

2000 Ruling 2000-0021363 - Spin-off butterfly

FORCO 1 and FORCO 2 will subsequently transfer their respective common shares of Canco and, accordingly, the underlying Canadian XXXXXXXXXX business, to IPO Co so that IPO Co can make a public offering in respect thereof of up to XXXXXXXXXX % of the shares of its capital stock. ...
Ruling

2001 Ruling 2001-0066693 - production services tax credit

Investors may choose to finance up to approximately XXXXXXXXXX % of their investment in Units by way of a Unit Loan from the Unit Lender. ...
Ruling

1999 Ruling 9924993 - XXXXXXXXXX BUTTERFLY - DIVISIVE REORGANIZATION

The taxation year-end of each taxpayer referred to herein; their social insurance number or tax account number, tax service office ("TSO") or taxation centre ("TC") of Revenue Canada at which each such taxpayer files its income tax return (TSO/TC) and the approximate amounts of the capital dividend account and refundable dividend tax on hand of each such corporate taxpayer at the end of its 1998 taxation year are set forth below: Taxpayer and (SIN/Account #) TSO/TC Year-End RDTOH CDA DC (XXXXXXXXXX) XXXXXXXXXX ABco (XXXXXXXXXX) XXXXXXXXXX Bco (XXXXXXXXXX) XXXXXXXXXX Asub (XXXXXXXXXX) XXXXXXXXXX Aco (XXXXXXXXXX) XXXXXXXXXX Cco (XXXXXXXXXX) XXXXXXXXXX Spousal Trust Ltd. ...
Ruling

30 November 1997 Ruling 9801803 - PUBLIC BUTTERFLY

+ D as found in subparagraph (b)(iii) of the definition of "permitted exchange" in subsection 55(1). ...
Ruling

2000 Ruling 2000-0048083 - butterfly reorganization

Z XXXXXXXXXX /PUBCO XXXXXXXXXX shares XXXXXXXXXX Trust * XXXXXXXXXX/PUBCO XXXXXXXXXX shares XXXXXXXXXX (XXXXXXXXXX /Mr. ...
Ruling

2002 Ruling 2002-0133083 - In-House Loss Utilization

On a particular day in late XXXXXXXXXX, each of Newlossco3 and Newlossco4 will issue demand notes payable, bearing interest at a rate of XXXXXXXXXX %, the Newlossco3 Note A and Newlossco4 Note A, respectively, to Opco for cash in the amount of the non-capital losses of each of Newlossco3 and Newlossco4 at that time (which will approximate the interest expense incurred by each of Newlossco3 and Newlossco4 on the Newlossco3 Note and Newlossco4 Note, respectively). 47. ...
Ruling

2023 Ruling 2021-0896671R3 - Sequential Butterfly Ruling: Real estate business

XXXXXXXXXX 2021-089667 XXXXXXXXXX Dear XXXXXXXXXX, Re: Advance Income Tax Ruling Sequential butterfly reorganizations XXXXXXXXXX (Collectively referred to as the “Taxpayers”) We are writing in response to your request for an advance income tax ruling (“Ruling request”) dated XXXXXXXXXX, and revised on XXXXXXXXXX, on behalf of the above-noted Taxpayers. ...

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