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Ruling

2021 Ruling 2020-0858741R3 - Post-Mortem Pipeline

As such, F’s deemed proceeds of disposition were $XXXXXXXXXX, pursuant to subparagraph 70(6)(b)(ii), resulting in $ XXXXXXXXXX capital gain for F’s XXXXXXXXXX taxation year. ...
Ruling

2023 Ruling 2020-0862441R3 - Charitable donation by Estate

XXXXXXXXXX 2020-086244 XXXXXXXXXX Dear XXXXXXXXXX: Re: CONTAINS TAXPAYER INFORMATION Advance Income Tax Ruling Subsection 84(2) and Charitable donation XXXXXXXXXX This is in reply to your letter dated XXXXXXXXXX in which you requested an advance income tax ruling (“Ruling”) on behalf of the above-named taxpayers. ...
Ruling

2021 Ruling 2021-0889011R3 - Redemption of MFT units held by registered plans

XXXXXXXXXX 2021-088901 XXXXXXXXXX, 2021 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request Redemption of Mutual Fund Trust Units Held by Registered Plans XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX requesting an advance income tax ruling (“Ruling”) on behalf of the above-named Taxpayer. ...
Ruling

2022 Ruling 2022-0947921R3 - Post-mortem tax planning

The number and classes of such shares and their FMV immediately before the Deceased’s death were as follows: Type of shares Class # of shares FMV Common Class 1 XXXXXXXXXX XXXXXXXXXX Common Class 2 XXXXXXXXXX XXXXXXXXXX Special Class A XXXXXXXXXX XXXXXXXXXX Special Class B XXXXXXXXXX XXXXXXXXXX Special Class C XXXXXXXXXX XXXXXXXXXX 6. ...
Ruling

2023 Ruling 2022-0958521R3 - foreign absorptive mergers

Step 9 there is no non-resident vendor and the purchaser is Taxpayer 6 for the acquisition of all issued and outstanding common shares of Taxpayer 11. 21. ...
Ruling

2023 Ruling 2023-0969661R3 - Post-mortem Pipeline

The tax attributes attached to the shares of Opco immediately before the Deceased’s death were as follows: Shareholder Number & Class of FMV ACB PUC Shares of Opco Deceased XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Deceased XXXXX Opco Class E Special Shares XXXXX XXXXXX XXXXX Deceased XXXXX Opco Class F Special Shares XXXXX XXXXXX XXXXX Deceased XXXXX Opco Class Z Special Shares XXXXX XXXXXX XXXXX Child 1 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Child 2 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Child 5 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Child 6 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Child 7 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX 7. ...
Ruling

2024 Ruling 2024-1009511R3 - Post-mortem Pipeline

XXXXXXXXXX 2024-100951 XXXXXXXXXX 2024 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Post-mortem pipeline XXXXXXXXXX We are writing in response to your request, dated XXXXXXXXXX, for an advance income tax ruling (Ruling) on behalf of the above-noted taxpayers. ...
Ruling

30 November 1996 Ruling 9640333 - DISTRESS PREFERRED SHARES

XXXXXXXXXX 9.The XXXXXXXXXX units of XXXXXXXXXX are owned by over XXXXXXXXXX individuals and corporations that deal at arm's length with XXXXXXXXXX. 10.The TSO, taxation centre ("TC"), and the Revenue Canada account number ("RCT #") of the various members of XXXXXXXXXX are as follows: Corporation TSO\TC RCT # XXXXXXXXXX 11.XXXXXXXXXX is a taxable Canadian corporation and a public corporation whose shares are listed for trading on the XXXXXXXXXX exchange. ...
Ruling

2023 Ruling 2022-0957571R3 - Cross-Border Butterfly

The aggregate FMV, immediately before the DC Transfer, of the Foreign Spinco XXXXXXXXXX owned by Forco 3 will be equal to or approximate the amount determined by the formula, on the assumption that Forco 3 is the participant, DC is the distributing corporation and Foreign Spinco is the acquiror, (A × B/C) + D as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1). ...
Ruling

2006 Ruling 2006-0178571R3 - Purchase of Target and Bump

Holders may put the Convertible Senior Notes to TARGET in exchange for cash on XXXXXXXXXX at a purchase price equal to XXXXXXXXXX % of the principal amount plus accrued and unpaid interest. ... HOLDCO 1 and SHAREHOLDER 2-SUBCO 1 hold respectively XXXXXXXXXX % and XXXXXXXXXX% of the issued and outstanding shares of the capital stock of FINANCECO. ...

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