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Ruling

2003 Ruling 2003-0045173 - health spending account

XXXXXXXXXX % of his or her salary, whichever is less. 18. The allocation will be further limited to the amount of the bonus ultimately determined for the Participating Executive in XXXXXXXXXX of the plan year. 19. ...
Ruling

2004 Ruling 2003-0054381R3 - Proposed variation of a trust

Yours truly, XXXXXXXXXX Section Manager For Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...
Ruling

2004 Ruling 2003-0050931R3 - Deferred self funded leave plan

The Employer contributes to a defined contribution pension plan (the Pension Plan) on behalf of its employees at the yearly rate of XXXXXXXXXX % of gross earnings. ...
Ruling

2004 Ruling 2004-0094751R3 - Withholding tax; interest

C-44, as amended; (h) "Corporate Act of Province A" means the XXXXXXXXXX Companies Act; (i) "CRA" means the Canada Customs and Revenue Agency, and after December 12, 2003, the Canada Revenue Agency; (j) "dollars" or "$" means Canadian dollars unless otherwise specified; (k) "Foreign Lender" means XXXXXXXXXX, a U.K. based commercial paper-funded corporation administered by Assignee; (l) "Newco" means a special-purpose corporation to be incorporated under the laws of the Province B; (m) "principal amount" has the meaning assigned by subsection 248(1); (n) "private corporation" has the meaning assigned by subsection 89(1); (o) "Province A" means the Province of XXXXXXXXXX; (p) "Province B" means the Province of XXXXXXXXXX; (q) "Province C" means the Province of XXXXXXXXXX; (r) "public corporation" has the meaning assigned by subsection 89(1); (s) "registered charity" has the meaning assigned by subsection 248(1); (t) "subsidiary wholly-owned corporation" has the meaning in subsection 248(1); (u) "TC" means Taxation Centre; (v) "Trust" means XXXXXXXXXX, as described in paragraph 3; (w) "Trustee" or "Trustee of the Trust" means XXXXXXXXXX, a corporation incorporated under the Corporate Act and a subsidiary of XXXXXXXXXX; and (x) "TSO" means Tax Services Office. ...
Ruling

2004 Ruling 2004-0093591R3 - Withholding - GP corporation on loans to LP

Under no circumstances (except in the event of default or if the terms of the debt or related agreement become unlawful or are changed by virtue of legislation or by a court, statutory board or commission) would GP be obligated to repay more than XXXXXXXXXX % of the principal amount of any of the obligations within XXXXXXXXXX years from the date of issue of each obligation. 14. ...
Ruling

2004 Ruling 2004-0058171R3 - Stock options - exchange

"Substituted Right" means a right which will entitle the Optionee to acquire on exercise the following number of Common Shares: Number of Common = Number of Common x (Current Price- Exercise Price) Shares Shares under the Current Price exchanged options XXXXXXXXXX Facts 1. ...
Ruling

2004 Ruling 2004-0074051R3 - variation of a grantor trust

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

2005 Ruling 2004-0105821R3 - Loss utilization

. $ XXXXXXXXXX of the accumulated non-capital losses was incurred in XXXXXXXXXX and the balance is a carry forward from XXXXXXXXXX. 4. ...
Ruling

2000 Ruling 2000-0043393 - SDA LONG TERM INCENTIVE PLAN

Yours truly, XXXXXXXXXX for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...
Ruling

2001 Ruling 2001-0069703 - LOSS CONSOLIDATION

These rulings are provided subject to the limitations and qualifications set out in Information Circular 70-6R4 issued by the Canada Customs & Revenue Agency on January 29, 2001 and are binding upon the Agency provided that the proposed transactions are completed on or before XXXXXXXXXX. ...

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