Search - 深圳居住证 办理条件 最新政策

The Distribution will be considered to be received as a dividend in respect of a class of shares of capital stock of FA1 by the Taxpayers (Canco7, 8 and 9) for the purposes of s. 212.3(9)(b)(ii) – A(B). ...

The Taxpayer will issue “Claim Settlement Shares” to Affected Creditors in satisfaction of their Affected Claims (except that “Cash Election Creditors” will receive cash in lieu of such shares – apparently funded out of common share subscriptions by the Plan Sponsor and investors), thereby resulting in a portion of the outstanding principal of the Affected Claims being forgiven The resulting forgiven amount is estimated to be less than the taxpayer’s tax attributes. ...

Had the Fund now held Opco directly, this would have been accomplished by incorporating a subsidiary (“MFC”), distributing relatively modest shareholdings in MFC to its unitholders sufficient to qualify MFC as a mutual fund corporation, amalgamating MFC and Opco so that Amalco MFC also qualifies as a mutual fund corporation, and then instigating the merger of Amalco MFC into the Fund under s. 132.2 – so that the former assets of Opco are now held directly by a REIT (the Fund). ...

2017 Ruling 2017-0699201R3- Cross-border Butterfly-- summary under Paragraph 212.1(1.1)(b) Summary Under Tax Topics- Income Tax Act- Section 212.1- Subsection 212.1(1.1)- Paragraph 212.1(1.1)(b) application on 4-party exchange CRA ruled on a cross-border butterfly which entailed assets of the “Transferred Business” being transferred indirectly to a wholly-owned non-resident subsidiary (Foreign Spinco) of a non-resident public company (Foreign Parentco) or to a wholly-owned non-resident subsidiary of Foreign Spinco (Foreign Spinco Sub) – with a view to the shares of Foreign Spinco being dividended out to the shareholders of Foreign Parentco at the transactions’ completion. ...

Such amount may be deducted, to the extent permitted by s. 146(8.9) – and the Executors may request a reassessment of the final return of the deceased if necessary to take these deductions into account. ...

The estate will make a substantial distribution to Trust1, Trust2, Trust3 and Trust4 through a distribution of inter alia Notes1 to 4 now owing by Newco – with such Trusts agreeing with Newco to pay the accrued but unpaid interest owing by then on Trust-Note1 to 4 to Newco, by way of set-off against part of Notes1 to 4 owing to them by Newco. ...

X did not wish his four children- who along with his wife and a family company were the beneficiaries of an inter vivos trust (“Trust 1”) holding shares of family companies – to be distributed the assets of Trust 1 (such shares) immediately before the 21 st anniversary of the settling of Trust 1. ...

The unwinding of the above loss consolidation arrangements will entail inter alia Newco redeeming its preferred shares with a note, which New LP will use to repay the New LP Loan by assigning it to Parent, with that note then being set off against the Parent Loan – and Newco and New LP being wound up. ...

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. ...