Search - 微信撤回和删除的区别 官方

. … Opco Before the [above] transfers of shares…Opco was controlled by a related group…consist[ing] of either A and B, or Holdco A and Holdco B. ...

Preliminarily to a Plan of Arrangement: Aco will transfer the Bco Notes (having an adjusted cost base equal to their principal) to a newly-incorporated CBCA corporation (Newco1) in consideration for the issuance of Newco1 common shares Aco will transfer its Newco1 common shares to Bco in consideration for the issuance of a nominal number of Bco common shares the paid-up capital of the Newco1 common shares will be reduced Newco1 will be wound-up into Bco, with Bco making a s. 80.01(4) election a CBCA corporation (New Aco) will be incorporated Under the Plan of Arrangement: convertible debentures owing by Aco will be converted into Aco common shares Aco (and New Aco on its behalf) will deliver or issue cash, Aco senior notes, Aco debentures exchangeable into New Aco common shares and New Aco common shares in exchange for the debt (which is then cancelled) of existing debt holders of Aco – with Aco thereafter issuing first preferred shares and notes to New Aco in consideration for the issuance of the New Aco common shares to such debt holders the pre-Arrangement common and preferred shares of Aco will be purchased by Aco in consideration for the delivery of New Aco common shares and cashless warrants to acquire New Aco common shares Rulings: ss. 40(2)(e.1) and 53(1)(f.1) will apply to the dispositions of the Bco Notes to Newco1, so that their ACB is preserved the extinguishment of the Bco Notes on the winding-up of Bco will not give rise to a forgiven amount (per s. 80.01(4)) interest on the debt issued by Aco to the former debt holders will be deductible provided the interest on the former debt was deductible capital losses arising to Aco under s. 111(4)(d) on the acquisition of its control by New Aco [i.e., because its first preferred shares are voting?] ...

The each will own ½ of the common shares of the "Project General Partner" of New LP and subscribe for an equal number of LP units. ...

Proposed transactions Although redacted, apparently Trust is amending its Unit terms to make them non-retractable and is eliminating the Special Voting Units from what it is authorized to issue – as well as authorizing the issuance of the Preferred Units. ...

Y could generally be allowed …. ...

2014 Ruling 2014-0518451R3- Loss consolidation-- summary under Paragraph 111(1)(a) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(1)- Paragraph 111(1)(a) losses transferred to new "Aco" which is wound-up into profitco – but borrowing capacity rep of Lossco not Aco/ provincial GAAR ruling/ cashless un-wind Overview Loan 2 (in step 3 below) is being made by Lossco (the wholly-owned loss subsidiary of Parent) to Aco (so as to generate losses in Aco for later transfer under s. 88(1.1) to Opco), instead of being made directly to Opco, "to ensure that Opco, which is a public corporation, does not incur debt in order to implement the loss utilization. ...

. … [The] trust structures designed to purposely invoke attribution pursuant to subsection 75(2), with a view to avoiding the payment of tax on extracted corporate dividends …typically involves two Canadian corporations and a trust that acquires shares in one of the corporations ("Corp A"). ...

. … Our conclusion would be the same if the transactions respecting a freeze of Opco in order to introduce Nephew were part of the series of transactions that included the deemed dividend received by Holdco as a result of the redemption of the Class "D" shares of the capital stock of Opco held by Holdco, as Nephew and Nephew Inc. were related to Holdco, the dividend recipient, by virtue of subparagraphs 251(2)(b)(iii) and 251(2)(c)(ii), respectively. ...

. … Justice L'Heureux-Dubé seemed to suggest that Mara Properties stands for the proposition that subsection 88(1) deems the parent to have received property of the same character from its subsidiary upon the subsidiary's wind-up. ...

Proposed transactions The terms of the Notes A will be amended (but with no novation) to change the governing law and to add a right allowing the holder to exchange them for new Canadian-dollar interest-bearing demand notes ("Notes B"); and a similar exchange right into Canco1 Note B will be added to Canco1 Note A – with both exchange rights then being exercised by Canco3. ...