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Ruling

1998 Ruling 9826013 - MUTUAL FUND TRUST

The key provisions of the Plan of Operation for each Fund are as follows: a) Section XXXXXXXXXX of the Plan of Operation provides that “Valuation Date" means the date on which the Trustee shall determine the value of each Fund as provided in section XXXXXXXXXX of the Plan of Operation; b) Section XXXXXXXXXX of the Plan of Operation provides that only trusts, the monies of which are in the care of the Trustee, may be participants in a Fund; c) Section XXXXXXXXXX of the Plan of Operation provides that each Fund is divided into units and the units are equal in value without distinction, preference or priority; d) Section XXXXXXXXXX of the Plan of Operation provides that participants may redeem any number of units of a Fund on any Valuation Date and at no other time at a price equal to the then unit value as determined by the Trustee and the number of units of the Fund shall be reduced accordingly; e) Section XXXXXXXXXX of the Plan of Operation provides that payment to a participant for units redeemed shall be in cash, but the Trustee has the right to make payment in the form of assets or a combination of cash and assets, provided that the proportion of any asset distributed in kind to a participant does not exceed the proportion that the total amount withdrawn bears to the then value of the Fund and the form of payment to all participants redeeming units as of a particular Valuation Date is the same; f) Section XXXXXXXXXX of the Plan of Operation provides that requests for redemption must be received by the Trustee at least five business days prior to the applicable Valuation Date; g) Section XXXXXXXXXX of the Plan of Operation provides that units of a Fund may not be redeemed if the result would be that less than XXXXXXXXXX % of the remaining assets of the Fund would be composed of cash and readily marketable securities; h) Section XXXXXXXXXX of the Plan of Operation provides that the Trustee must determine the value of a Fund and of its units not less frequently than once each calendar month; i) Section XXXXXXXXXX of the Plan of Operation provides that the value of a unit as of a Valuation Date is determined by dividing the value of a Fund by the number of units of such Fund then outstanding; j) Section XXXXXXXXXX of the Plan of Operation provides that the computations necessary to determine the value of a Fund and its units must be made within a period of XXXXXXXXXX business days following each Valuation Date; k) Section XXXXXXXXXX of the Plan of Operation sets out certain general investment restrictions, including the following: i) The investment of a Fund in guaranteed investment certificates of any trust company, debentures of any loan company, or bonds of or guaranteed by any municipal corporation shall not exceed in each case XXXXXXXXXX % of the book value of a Fund; ii) The total investment of a Fund in stocks or bonds or other obligations of, or guaranteed by any one person, other than the obligations referred to in (i) above, shall not exceed XXXXXXXXXX % of the book value of the Fund, iii) The limitations described in (i) and (ii) above shall not apply to investments in obligations of or guaranteed by the government of Canada or any province of Canada, or evidences of indebtedness issued by a Canadian chartered bank which are cashable on demand; iv) The total number of shares held by a Fund or the Funds in any one class of shares or stock of any one corporation shall not exceed XXXXXXXXXX % of the number of such shares outstanding; and v) Not less than XXXXXXXXXX % of the book value of a Fund is required to be maintained in cash and readily marketable securities; l) Section XXXXXXXXXX of the Plan of Operation provides that in addition to the general limitations otherwise applicable, the Trustee shall invest and reinvest the monies of each Fund in accordance with the provisions of the Schedule attached to the Plan of Operation for each Fund; m) Section XXXXXXXXXX of the Plan of Operation provides that where any security held in a Fund has become an ineligible investment for that Fund and that state of ineligibility has continued for six months, no further admissions or withdrawals are permitted from the Fund until after the security has again become eligible or has been eliminated from the Fund; n) Section XXXXXXXXXX of the Plan of Operation provides that the Trustee may amend the Plan of Operation from time to time with the approval of such persons whose approval is required by law; and o) Schedules XXXXXXXXXX of the Plan of Operation provide, respectively, for certain of the Funds. ...
Ruling

30 November 1996 Ruling E9725063 - splitting up a mutual fund trust

The following table sets forth the number of Corporation 2 Unitholders and T2 Unitholders who hold units in each of the Relevant Fund 2 Sections and the proportion of the total units of each Relevant Fund 2 Section that is held by each group of unitholders as at XXXXXXXXXX: Relevant Fund 2 Section No. of T2 Unitholders No. of Corporation2 Unitholders NAV of Units held by T2 Unitholders NAV of Units held by Corporation 2 Unitholders % of Units Held by T2 Unitholders % of Units Held by Corporation 2 Unitholders Fund A XXXXXXXXXX XXXXXXXXXX Fund B XXXXXXXXXX XXXXXXXXXX Fund C XXXXXXXXXX XXXXXXXXXX Fund D XXXXXXXXXX XXXXXXXXXX Fund E XXXXXXXXXX XXXXXXXXXX Fund F XXXXXXXXXX XXXXXXXXXX Fund G XXXXXXXXXX XXXXXXXXXX 13. ... The following table sets forth the number of Corporation 1 Unitholders and T1 Unitholders who hold units in each of the Relevant Fund 1 Sections and the proportion of the total units of each Relevant Fund 1 Section that is held by each group of unitholders as at XXXXXXXXXX: Relevant Fund 1 Section No. of T1 Unitholders No. of Corporation 1 Unitholders NAV of Units held by T1 Unitholders NAV of Units held by Corporation 1 Unitholders % of Units Held by T1 Investment Unitholders % of Units Held by Corporation 1 Unitholders Fund H XXXXXXXXXX XXXXXXXXXX Fund I XXXXXXXXXX XXXXXXXXXX Fund J XXXXXXXXXX XXXXXXXXXX Fund K XXXXXXXXXX XXXXXXXXXX 23. ...
Ruling

30 November 1996 Ruling 9725063 - splitting up a mutual fund trust

The following table sets forth the number of Corporation 2 Unitholders and T2 Unitholders who hold units in each of the Relevant Fund 2 Sections and the proportion of the total units of each Relevant Fund 2 Section that is held by each group of unitholders as at XXXXXXXXXX: Relevant Fund 2 Section No. of T2 Unitholders No. of Corporation2 Unitholders NAV of Units held by T2 Unitholders NAV of Units held by Corporation 2 Unitholders % of Units Held by T2 Unitholders % of Units Held by Corporation 2 Unitholders Fund A XXXXXXXXXX XXXXXXXXXX Fund B XXXXXXXXXX XXXXXXXXXX Fund C XXXXXXXXXX XXXXXXXXXX Fund D XXXXXXXXXX XXXXXXXXXX Fund E XXXXXXXXXX XXXXXXXXXX Fund F XXXXXXXXXX XXXXXXXXXX Fund G XXXXXXXXXX XXXXXXXXXX 13. ... The following table sets forth the number of Corporation 1 Unitholders and T1 Unitholders who hold units in each of the Relevant Fund 1 Sections and the proportion of the total units of each Relevant Fund 1 Section that is held by each group of unitholders as at XXXXXXXXXX: Relevant Fund 1 Section No. of T1 Unitholders No. of Corporation 1 Unitholders NAV of Units held by T1 Unitholders NAV of Units held by Corporation 1 Unitholders % of Units Held by T1 Investment Unitholders % of Units Held by Corporation 1 Unitholders Fund H XXXXXXXXXX XXXXXXXXXX Fund I XXXXXXXXXX XXXXXXXXXX Fund J XXXXXXXXXX XXXXXXXXXX Fund K XXXXXXXXXX XXXXXXXXXX 23. ...
Ruling

2002 Ruling 2002-0177163 - Subsection 87(4) - S/H Rights Plan

The Separation Time is the close of business on the XXXXXXXXXX business day (or such later date as is determined by the directors of Parent) after the earlier of: (a) the first date of the public announcement that a person (an "Acquiring Person", which term excludes certain specified persons) has become the beneficial owner of XXXXXXXXXX % or more of the Common Shares, or, if already the beneficial owner of XXXXXXXXXX % or more of the Common Shares, becomes the beneficial owner of more than an additional XXXXXXXXXX% of the Common Shares (such acquisition being a Flip-in Event and the date of such public announcement being the "Stock Acquisition Date"); (b) the date of commencement of, or the first public announcement of the intent of any person (other than certain specified persons) to commence, a takeover bid (other than a takeover bid which is or becomes a "Permitted Bid" (as defined in the Plan) or a "Competing Permitted Bid" (as defined in the Plan) or a takeover bid in respect of which the directors of Parent have determined to waive the application of the Plan); and (c) the date upon which a Permitted Bid ceases to be a Permitted Bid. ... Under the Plan, a Permitted Bid is: (a) a takeover bid made by means of a takeover bid circular by a person who beneficially owns, and has owned within the prior XXXXXXXXXX months, XXXXXXXXXX % or less of the Common Shares; (b) a bid for all the outstanding Common Shares which is open for acceptance for not less than XXXXXXXXXX days; and (c) one which provides that more than XXXXXXXXXX% of the Common Shares held by "Independent Shareholders" (as defined in the Plan) must be deposited to the takeover bid and not be withdrawn and that the offeror will make a public announcement of that fact and the takeover bid will then remain open for deposits of Common Shares for not less than XXXXXXXXXX business days from the date of such public announcement. ...
Ruling

2010 Ruling 2010-0384371R3 - Supplementary Ruling

The authorized share capital of DC consists of: (a) an unlimited number of voting, common shares; (b) an unlimited number of Class A preference shares that are non-voting, XXXXXXXXXX % non-cumulative redeemable shares; and (c) an unlimited number of Class B preference shares that are non-voting, XXXXXXXXXX % non-cumulative redeemable shares. ...
Ruling

2009 Ruling 2009-0342011R3 - Structured Settlement

The Plaintiff, XXXXXXXXXX, has reached a settlement with the Defendant with respect to his claim, subject to receipt of a favourable income tax ruling with respect to the periodic payments under the settlement, in accordance with the "XXXXXXXXXX " (the "Minutes of Settlement"). 5. The terms of the Minutes of Settlement provide for periodic payments to or for the benefit of the Plaintiff, consisting of lifetime monthly payments, starting at $XXXXXXXXXX per month and indexed at a rate of XXXXXXXXXX % per year. ...
Ruling

2005 Ruling 2005-0125481R3 F - Cotisation syndicale

Chaque XXXXXXXXXX a établit une caisse XXXXXXXXXX (ci-après "Caiss "), conformément aux disposition des conventions collectives XXXXXXXXX, afin de comptabiliser les cotisations reçues des salariés en vertu de la clause XXXXXXXXXX de leur convention collective (ou l'équivalent de cette clause). 11. ... La cotisation de XXXXXXXXXX $ de l'heure travaillée doit être payée par chaque salarié oeuvrant dans les secteurs XXXXXXXXXX. 15. ...
Ruling

30 November 1996 Ruling 9714033 F - PARTAGE REER DIVORCE

Monsieur A, qui vit séparément de Madame B, est tenu de lui verser aux termes d'une convention sur mesures accessoires entérinée par le jugement de divorce (la "Convention"), une pension alimentaire hebdomadaire de XXXXXXXXXX $. TRANSACTIONS PROJETÉES 3.Monsieur A et Madame B vont modifier la Convention (la "Convention modifiée") afin que Monsieur A puisse verser un montant forfaitaire à Madame B en règlement complet et final de la pension alimentaire que Monsieur A est tenu de verser. 4.Le paiement du montant forfaitaire sera effectué par le transfert de biens du régime enregistré d'épargne-retraite (REER) non échu de Monsieur A d'une valeur d'environ XXXXXXXXXX $ dans un REER dont Madame B sera rentière. ...
Ruling

30 November 1996 Ruling 9713103 F - ACTIONS PRIVILÉGIÉES DE DÉTRESSE

FILCO XXXXXXXXXX et FILCO XXXXXXXXXX utiliseront le produit de la vente de chacun des prêts pour acheter pour annulation les actions privilégiées de détresse à un prix égal à XXXXXXXXXX $ l'action et en plus, verseront les dividendes courus et non payés sur ces actions, plus tout montant additionnel susmentionné relativement à ces actions. ... FILCO XXXXXXXXXX et FILCO XXXXXXXXXX utiliseront le produit de la vente de chacun des prêts pour acheter pour annulation les actions privilégiées de détresse à un prix égal à XXXXXXXXXX $ l'action. ...
Ruling

2001 Ruling 2000-0059963 - Disclaimer of Capital Interest

Disclaiming beneficiary will not be considered to have received any proceeds of disposition for purposes of section 106 & 107; disclaimed interest will be considered to have been received "as a consequence of death for the purpose of 248(8); donation will qualify under 118.1; GAAR is not applicable. ... X was filed at the XXXXXXXXXX Tax Services Office under his Social Insurance Number XXXXXXXXXX; (b) " Estate Trustees" of the Estate of Mr. ...

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