Search - 深圳居住证 办理条件 最新政策
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Ruling
2007 Ruling 2007-0231331R3 - Amalgamation and bump
New Subco 1's authorized capital consists of an unlimited number of voting and fully participating common shares; "Non-Resident" means: (i) a person (within the meaning of subsection 248(1) but, for greater certainty, not including a partnership) who is not resident in Canada for the purposes of the Act; or (ii) a partnership that is not a "Canadian partnership" as defined in subsection 248(1); "Other Shareholders" means XXXXXXXXXX which directly or indirectly owned approximately XXXXXXXXXX % of the total Target Shares, XXXXXXXXXX. which directly or indirectly owned approximately XXXXXXXXXX% of the total Target Shares and Management who never owned directly or indirectly more than approximately XXXXXXXXXX% of the total Target Shares from XXXXXXXXXX until the Effective Time. ...
Ruling
2006 Ruling 2006-0190371R3 - Reorganization of a mutual fund trust - s. 132.2
Yours truly, XXXXXXXXXX Section Manager For Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling
2006 Ruling 2005-0162951R3 - Single-wing butterfly
The issued and outstanding shares of DC are owned as follows: Shareholder Common Shares Preferred Shares % of Class Individual1 XXXXXXXX XXXXXXXX XXXXXXXX Holdco1 XXXXXXXX XXXXXXXX XXXXXXXX Individual2 XXXXXXXX XXXXXXXX XXXXXXXX Holdco2 XXXXXXXX XXXXXXXX XXXXXXXX Individual3 XXXXXXXX XXXXXXXX XXXXXXXX Holdco3 XXXXXXXX XXXXXXXX XXXXXXXX Individual4 XXXXXXXX XXXXXXXX XXXXXXXX Holdco4 XXXXXXXX XXXXXXXX XXXXXXXX Each of the shareholders of DC holds its shares of DC as capital property. ...
Ruling
2006 Ruling 2006-0172931R3 - income trust reorganization
XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling
2005 Ruling 2004-0070981R3 - Conversion to MFT
The members of the Partnership are Opco (as to an approximate XXXXXXXXXX% interest), Sub 1 (as to an approximate XXXXXXXXXX % interest), Sub 3 (as to an approximate XXXXXXXXXX% interest) and Sub 2 (as to an approximate XXXXXXXXXX% interest). ...
Ruling
2005 Ruling 2005-0114861R3 - Butterfly - XXXXXXXXXX
To date XXXXXXXXXX Class C Shares owned by Sibling2 have been transferred to Holdco and redeemed by DC pursuant to the Class C Redemption Agreement as follows: DC's Taxation Year # of Class C Shares Redeemed XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Subtotal XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Total XXXXXXXXXX None of the above-described redemptions of Class C Shares have taken place in contemplation of, or in connection with, the Proposed Transactions. ...
Ruling
30 November 1995 Ruling 9611353 F - REORGANISATION "SOMERSAULT"
XXXXXXXXXX 14.En date des présentes, les caractéristiques fiscales des actions émises et en circulation de XXXXXXXXXX sont les suivantes: Nombre d'actions Capital versé Prix de base rajusté Actions ordinaires XXXXXXXXXX 15.La direction de XXXXXXXXXX estime que la juste valeur marchande des actions de XXXXXXXXXX est approximativement de XXXXXXXXXX $. ...
Ruling
30 November 1995 Ruling 9620363 - DISTRESS PREFERRED SHARES
The operating line is payable on demand and has an interest rate of prime + XXXXXXXXXX%. ...
Ruling
30 November 1996 Ruling 9709193 - BUTTERFLY REORGANIZATION
As at XXXXXXXXXX, the value of the assets and liabilities of XXXXXXXXXX, after giving effect to the sale of the XXXXXXXXXX property described in paragraph 21 below and adjusting the value of XXXXXXXXXX real property to fair market value were as follows: XXXXXXXXXX ** Liabilities, immediately before the transfers of property described in paragraph 34 below (the "Butterfly Transfer"), will include an amount in respect of taxes payable as a consequence of the sale of the XXXXXXXXXX property and the transfer of inventory properties in the course of the proposed transactions. 8. ...
Ruling
30 November 1997 Ruling 9813283 - BUTTERFLY
Immediately after the share-for-share exchange referred to in this Paragraph, the fair market value of the shares of the capital stock of XXXXXXXXXX Newco acquired by XXXXXXXXXX will equal or approximate the amount determined by the formula (A X B) + D C as found in paragraph (b)(iii) of the definition of permitted exchange. ...