Search - 哈尔滨到北京 公里数

LPco formerly held one Class B limited partner unit in each of the LP Purchasers, Master LP and Holding LP before the transactions described in paragraphs 13 and 20; "LPs Purchasers" means LP I, LP II, LP III, LP V, LP VI, LP VII and LP VIII; "LPs Purchasers LP Units" means the Class A limited partner units issued by each of the LP Purchasers to Trust I, as described in paragraph 16; "Master LP" means XXXXXXXXXX, a limited partnership with a fiscal period end of XXXXXXXXXX, formed under the laws of the province of XXXXXXXXXX to acquire, invest in and XXXXXXXXXX; "Master LP Units" means the Class A limited partner units of Master LP that were issued to Trust I, as described in paragraph 21; "XXXXXXXXXX Interest Partnership" means Parent's XXXXXXXXXX % XXXXXXXXXX interest in the XXXXXXXXXX before the transfer to Holding LP described in paragraph 25; "net capital loss" has the meaning assigned by subsection 111(8); "Net Realized Capital Gains" means, as defined in section 1.1 of the Trust I Contract of Trust, the amount for any period, if any, by which the capital gains of Trust I for the period exceeds the aggregate of the amount of any capital losses of Trust I for the period determined in accordance with the Act; "New Parent" means the resulting corporation from the amalgamation of Parent and Subco, as described in paragraph 39; "New XXXXXXXXXX " means XXXXXXXXXX trust that was established on XXXXXXXXXX, with a contribution of $XXXXXXXXXX by XXXXXXXXXX. ... "New Trust V" means a trust established under the laws of XXXXXXXXXX for the exclusive benefit of Trust I XXXXXXXXXX; "New Trust VI" means a trust established under the laws of XXXXXXXXXX for the exclusive benefit of Trust I XXXXXXXXXX; "New Trust VII" means a trust established under the laws of XXXXXXXXXX for the exclusive benefit of Trust I XXXXXXXXXX; "New Trust VIII" means a trust established under the laws of XXXXXXXXXX for the exclusive benefit of Trust I XXXXXXXXXX; XXXXXXXXXX; "Parent" means XXXXXXXXXX corporation continued under the laws of XXXXXXXXXX; "Parent's Partnerships" means the following partnerships in which Parent has an interest: XXXXXXXXXX "Parent's Partnership Units" mean the following partnership units of the Parent's Partnerships: XXXXXXXXXX XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; "XXXXXXXXXX GP" means XXXXXXXXXX, a corporation all shares of which are owned by New XXXXXXXXXX; "XXXXXXXXXX LP" means XXXXXXXXXX, a limited partnership created on XXXXXXXXXX with New XXXXXXXXXX and XXXXXXXXXX GP as the initial limited partner and general partner, respectively; "XXXXXXXXXX LP Units" means the Class A limited partner units of XXXXXXXXXX LP that were initially issued to Holding LP and Master LP, as described in paragraph 28; "XXXXXXXXXX " has the meaning assigned by subsection 248(1); "XXXXXXXXXX " has the meaning assigned by subsection 248(1); "Sisterco" means XXXXXXXXXX, a corporation incorporated under the laws of XXXXXXXXXX. ... Yours truly, for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

The Class C shares are non-voting and entitled to discretionary non-cumulative dividends of up to XXXXXXXXXX % of the redemption amount annually. ... The Class F shares are non-voting and entitled to discretionary non-cumulative dividends of up to XXXXXXXXXX % of the redemption amount annually. ... DC owns XXXXXXXXXX % of JV1 and XXXXXXXXXX % of JV2. Gains, profits and losses are reported by each of the JV participants on the basis of their proportionate ownership in the JV. ...

XXXXXXXXXX 2014-056128 XXXXXXXXXX 2014 Monsieur, Objet: Demande de décisions anticipées en matière d'impôt sur le revenu supplémentaire XXXXXXXXXX La présente fait suite à vos courriels du XXXXXXXXXX aux termes desquels vous nous avez demandé d'apporter une modification à l'un des éléments décrits au paragraphe 39 dans la partie Autres opérations envisagées de notre lettre du XXXXXXXXXX 2014 portant le numéro 2014-052929 (ci-après la « Lettre »). ...

XXXXXXXXXX 2010-035718 XXXXXXXXXX, 2010 Dear XXXXXXXXXX: Re: Supplementary Advance Income Tax Ruling XXXXXXXXXX (the "Partnership") XXXXXXXXXX (the " Electing Partners") We are writing in response to your recent letter in which you requested amendments to Advance Income Tax Ruling 2009-031826 (the "Ruling"). ...

XXXXXXXXXX 2017-070435 XXXXXXXXXX, 2017 Dear XXXXXXXXXX: Re: XXXXXXXXXX Advance Income Tax Ruling – Supplement to 2016-067588 We are writing in response to your letter of XXXXXXXXXX wherein you advised us of certain changes to the facts in Advance Income Tax Ruling 2016-067588 (the “AITR”). ...

Prud'Homme / XXXXXXXXXX) relativement à ce dossier. Dans votre demande de décisions anticipées, l'opération projetée consiste à modifier les statuts de XXXXXXXXXX. ...

7 June 1993 Ruling 9315201 F- Joint Exploration Corporation Unedited CRA Tags 66(10), 66(12.73), 66(15) joint exploration corporation, 163(2.2)   Issue Sheet 1993 CPTS Roundtable June 17, 1993 RE:  Joint Exploration Corporation Agreed Portion of Resource Expense Question #34  Subsection 163(2.2) of the Act imposes a penalty, in certain circumstances, where a joint exploration corporation ("JEC") renounces a greater amount of expenses than it was entitled to renounce. ...

The reference to "Act" in paragraph 3 is hereby deleted and replaced by " Income Tax Act (the "Act")". 4. ...

" The Supreme Court of Canada found in Savage, 83 DTC 5409 and Nowegijick, 83 DTC 5041 that the words "in respect of" are "... of the widest possible scope". ...

Paragraph 6 of the PROPOSED TRANSACTIONS is amended as follows: ACO will use its available funds to make loans to CCO aggregating $XXXXXXXXXX, bearing interest at XXXXXXXXXX %. ...