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Ruling summary

2020 Ruling 2020-0844081R3 F - Rollout of property to beneficiaries -- summary under Subsection 107(2)

All the Class D shares of Zco held by Trust 2 were exchanged under s. 51 for Class D non-voting and participating shares, Class E non-voting preferred shares and Class F preferred shares (bearing a dividend that was potentially discretionary) and then made a further s. 51 exchange of Class D for Class D and E shares. ...
Ruling summary

2012 Ruling 2012-0452291R3 - XXXXXXXXXX - ATR -- summary under Subsection 17(2)

Pubco (acting through a branch in Country 1 assumed here to be Luxembourg) will subscribe with cash for common shares and/or mandatorily redeemable preferred shares ("MRPS") of Finco. ...
Ruling summary

2013 Ruling 2013-0491651R3 - Cross-Border Butterfly -- summary under Distribution

In determining the net FMV of each type of property of DC and its subsidiaries (anticipated to be cash or near-cash property and business property), (a) the net FMV of any accounts receivable, trade receivables, inventories and prepaid expenses of such corporation or partnership remaining after the allocation of current liabilities to cash or near-cash property will be reclassified as business property "to the extent that such property will be collected, sold, used or consumed in the ordinary course of business to which such property relates," and (b) any current ("as determined by the method prescribed by the applicable pension legislation") pension plan, post-retirement benefit or liability insurance liabilities of DC will be allocated to cash or near-cash property, and any such liabilities of a non-current nature will be allocated to business property and similarly for employee incentive plans. ...
Ruling summary

2014 Ruling 2014-0533601R3 - Spin-off butterfly - subsection 55(2) -- summary under Distribution

Proposed transactions The following transactions will occur under a Plan of Arrangement to accomplish a spin-off of Subco 1 and 2 Transferred Business through Spinco, which was incorporated but has no shareholders: Under a s. 86 reorganization, each DC shareholder will exchange all of its DC common shares for "DC Butterfly Shares" and Class D, E or F common shares (with the aggregate paid-up capital of the exchanged shares being apportioned), such that the aggregate fair market value of the DC Butterfly Shares will be equal to the "Butterfly Ratio" (equal to the relative net FMV of Subco 1 Transferred Business 1 and 2) multiplied by the aggregate FMV of all the DC shares held immediately before the exchange and the FMV of the Class D, E or F common shares received on the exchange will capture the balance of the FMV of the exchanged Class A, B or C common shares. ...
Ruling summary

2015 Ruling 2015-0604051R3 - Internal Reorganization -- summary under Subparagraph 55(3)(a)(iii)

Rulings The s. 55(3)(a) exception will apply to the dividends in 1, 3 and 7, provided there is not a disposition of property or an increase in interest described in ss. 55(3)(a)(i) to (v) which is part of the series of transactions or events and the proposed transactions, by themselves, will not be considered to result in any disposition to, or increase in interest by, an unrelated person described in ss. 55(3)(a)(i) to (v). ...
Ruling summary

2021 Ruling 2021-0911211R3 - Foreign Takeover -- summary under Adjusted Cost Base

By virtue of the First Merger, each common and preferred share of Target was converted into the right to receive the applicable “Merger Consideration,” being the “Share Consideration” (being common shares to be issued by XXXXXXXXXX being the direct (apparently Canadian-resident) parent of Opco referred to herein as Parent) and the “Cash Consideration.” ...
Ruling summary

2023 Ruling 2022-0957491R3 F - Butterfly Reorganization -- summary under Distribution

Transferor will transfer a pro rata portion of its two types of property to Child 1 Holdco and Child 2 Holdco on a s. 85(1) rollover basis in consideration in each case for preferred shares of the respective Holdco and the assumption of ½ of the Estate Note and Trust Note, so that the two notes will be extinguished by operation of law. ...
Ruling summary

2014 Ruling 2014-0530961R3 - Cross-Border Butterfly -- summary under Distribution

In order that the butterfly transactions could qualify as a tax-free spin-off for Code purposes, TC (a ULC) and Foreign Spinco (an LLC) initially were fiscally transparent for Code purposes then TC elected to be fiscally regarded in order that it could qualify for Treaty benefits and the Foreign Spinco became a C-corp in order that its spin-off could comply with Code rules. ...
Ruling summary

2016 Ruling 2015-0616291R3 - Cross-Border Butterfly -- summary under Distribution

Canadian DC holds 3 of the quotas in the capital of Forco 3 and the balance are held by Forco 1 and otherwise does not hold any shares or units. ...

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