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Ruling

2009 Ruling 2009-0307001R3 - Carrying on Business in Canada

Yours truly, for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling

2007 Ruling 2007-0232421R3 - bargain purchase under a will

XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling

2007 Ruling 2007-0250671R3 - Structured Settlement

The Plaintiff, a minor, by XXXXXXXXXX Litigation Guardian, XXXXXXXXXX commenced an action by Statement of Claim issued XXXXXXXXXX in the Superior Court of Justice (Action # XXXXXXXXXX) against XXXXXXXXXX, which action was subsequently only pursued against XXXXXXXXXX (the "Defendant"). ...
Ruling

2008 Ruling 2007-0234061R3 - Cost reimbursement - innovative instrument

The Special Trust Securities will at all times represent not more than XXXXXXXXXX % of all of the issued units of the Trust (determined by fair market value and without regard to any voting rights attaching to the units of the Trust). ...
Ruling

2006 Ruling 2006-0186631R3 - Eligibility for OETC

Yours truly, XXXXXXXXXX For Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling

2006 Ruling 2006-0178791R3 - Notes linked to Commodity Index

C. 1985(5th Supp.) c.1, as amended to the date hereof; (b) "A Co" means XXXXXXXXXX and is further described in 1 to 3 below; (c) "CRA" means the Canada Revenue Agency; (d) "Final Index Value" means the value of the Index on the Maturity Date of the Note; (e) "Index" means a particular commodity index XXXXXXXXXX (together referred to as the Indexes) and is further described in 8 below; (f) "Index Return" means the positive or negative amount which is calculated based on the change in the value of the Index between the Initial Index Value and Final Index Value as described in 7 below; (g) "Issue Date" means the date a Depositor advances an amount to A Co and the Notes are issued; (h) "Initial Index Value " means the value of the Index on the Issue Date of the Note; (i) "Maturity Date" means a date that is a stipulated date one year after the Issue Date; (j) "Notes" means the Notes to be issued and are further described in 4 to 10 below; (k) XXXXXXXXXX; and, (l) "Regulations" mean the Income Tax Regulations. ...
Ruling

2006 Ruling 2006-0210561R3 - Witholding Tax Exemption

Paragraph 28c)(iii) of the proposed transactions is replaced by the following: Commencing with the fiscal year ended before XXXXXXXXXX, from excess cash flow (ECF) as per the table below; Leverage Ratio Cash Sweep XXXXXXXXXX The first sentence of paragraph 28c)(iv) of the proposed transactions is replaced by the following: During the XXXXXXXXXX-year period commencing on the Closing Date, principal repayments as described in b) above applied to the outstanding loans under the Finco Tranche of the Term Facility or repaid as a result of the application of any of the mandatory repayment provisions other than as a result of an acceleration following an Event of Default cannot exceed XXXXXXXXXX % of the Finco Tranche of the aggregate principal amount of the Term Facility on the Closing Date. ...
Ruling

2005 Ruling 2004-0100611R3 - Payment to Australia

The unit price for 1-2 copies of the Software is $XXXXXXXXXX USD + $XXXXXXXXXX USD shipping. ...
Ruling

2005 Ruling 2005-0126121R3 - Supplemental ruling

Add the following Paragraphs following Paragraph 38: 38.1 Opco will borrow from an arm's-length lender or lenders an amount of money that will not exceed the amount of Opco's Adjusted Equity at that time. 38.2 Opco will use the money borrowed, as described in Paragraph 38.1, to effect a return of capital and the payment of a dividend to AcquisitionCo. 38.3 Acquisitionco will use the money received from Opco, as described in Paragraph 38.2, to repay to the Trust a portion of the principal amount outstanding in respect of the Trust Notes. 38.4 The Trust will then advance the money received from Acquisitionco, as described in Paragraph 38.3, to Opco in consideration for promissory notes of Opco (the " Trust Notes, Series One") having a principal amount equal to the amount of money advanced and having terms and conditions that are otherwise identical to those of the Trust Notes. 38.5 Opco will use the money advanced to it by the Trust, as described in Paragraph 38.4, to repay the indebtedness to the lender or lenders described in Paragraph 38.1. ...
Ruling

2005 Ruling 2005-0146021R3 - ATR-Deduct. of Shareholder/Manager Remuneration.

The shareholdings of Direct Shareholder D are as follows: Shareholders Common Shares % Indirect Shareholder A XXXXXX XXXXXXX Indirect Shareholder B XXXXXX XXXXXXX Indirect Shareholder C XXXXXX XXXXXXX Total XXXXXX XXXXXXX 13. ...

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