Search - 水晶光电 行业地位 发展趋势

30 October 1992 Income Tax Severed Letter 2M0333A- Published Version of 1991 Canadian Tax Foundation Unedited CRA Tags 30 / Various / Divers Revenue Canada Round Table Table Ronde de Revenu Canada* Robert M. ...

XXXXXXXXXX There are XXXXXXXXXX FCo XXXXXXXXXX Shares; “eligible property” has the meaning assigned by subsection 85(1.1); “ First Act ” means the Canada Business Corporations Act; “First Exchange” means XXXXXXXXXX; “forgiven amount” has the meaning assigned by subsections 80(1) and 80.01(1); “Fund Trustees” means a group of XXXXXXXXXX persons who will be elected by Unitholders in accordance with the Fund Declaration of Trust to act as trustees of New Fund, subject to the terms of the XXXXXXXXXX Agreement. ...

LP4 owns an interest in joint ventures, mortgages receivable and land inventory which include the following: • XXXXXXXXXX. ... The issued and outstanding share capital of Holdco 2 is held as follows: Shareholder Class of Shares Number of Shares Owned PUC = ACB Siblingco 2 Class A common XXXXXXXXXX XXXXXXXXXX Class A preference XXXXXXXXXX XXXXXXXXXX Class C preference XXXXXXXXXX XXXXXXXXXX Class D preference XXXXXXXXXX XXXXXXXXXX Class F-1 preference XXXXXXXXXX XXXXXXXXXX Class G preference XXXXXXXXXX XXXXXXXXXX Siblingco 3 Class A common XXXXXXXXXX XXXXXXXXXX Class A preference XXXXXXXXXX XXXXXXXXXX Class C preference XXXXXXXXXX XXXXXXXXXX Class D preference XXXXXXXXXX XXXXXXXXXX Class F-2 preference XXXXXXXXXX XXXXXXXXXX Class G preference XXXXXXXXXX XXXXXXXXXX Indirect Holdco 6 Sub Class E preference XXXXXXXXXX XXXXXXXXXX The Class A common shares of Holdco 2 are voting (XXXXXXXXXX vote per share), while all of the preference shares are non-voting and non-convertible. 17. ...

The aggregate FMV, immediately before the transfer of the Newco Common Shares by Canco to Tco described in Paragraph 44, of the Foreign Spinco membership interests owned by Foreign Pubco will be equal to or approximate the amount determined by the formula, on the assumption that Foreign Pubco is the participant, Canco is the distributing corporation and Foreign Spinco is the acquiror, (A x B/C) + D as found in subparagraph (b)(iii) of the definition of "permitted exchange" in subsection 55(1). 33. ...

DC has estimated its tax accounts as of XXXXXXXXXX as follows: (a) RDTOH – $XXXXXXXXXX (b) GRIP- $XXXXXXXXXX (c) CDA- $XXXXXXXXXX (d) pre-1972 CSOH- $XXXXXXXXXX Specifically, DC will not have any CDA or pre-1972 CSOH balance immediately before the Proposed Transactions. ...

XXXXXXXXXX; "US Treaty" means the Canada – United States Tax Convention (1980), as amended by the Protocols thereto. ...

In the present case, the phrase "dependent … on …sales of goods" could thus, as argued by counsel for the respondent, include payments which are dependent on the sales of goods by third parties, like the sales by the manufacturers to Hasbro. ...

Immediately before the transfer of the Newco Common Shares by DC to TC as described in Paragraph 80, the aggregate FMV of the Foreign Spinco Parent common shares owned by Foreign Pubco will be equal to or approximate the amount determined by the formula, on the assumption that Foreign Pubco is the participant, DC is the distributing corporation, Foreign Spinco Parent is the acquiror and the distribution is the transfer of Newco Common Shares described in Paragraph 80, (A x B/C) + D As found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1). 72. ...

Prior to entering into the Proposed Transactions, the issued and outstanding shares of the capital stock of DC, which represent Capital Property to its shareholders, will be held as follows: Shareholder # Common Shares PUC ACB FMV SCo XXXXX $XXXXX $XXXXX $XXXXX WCo XXXXX $XXXXX $XXXXX $XXXXX 4. ...

DC’s assets consist of the following: (a) cash; (b) income taxes receivable; (c) marketable securities; (d) XXXXXXXXXX percent (XXXXXXXXXX %) of the issued and outstanding shares of the capital stock of XXXXXXXXXX, a CCPC; (e) furniture having a FMV of $XXXXXXXXXX; and (f) XXXXXXXXXX 3. ...