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Ruling
2002 Ruling 2002-0126853 - PATRONAGE DIVIDENDS
Subject to adjustments as contemplated in the Agreements, DCO will pay a membership fee in the amount of $XXXXXXXXXX plus XXXXXXXXXX % of audit and legal fees, and BCO will pay a membership fee in the amount of $XXXXXXXXXX plus XXXXXXXXXX% of audit and legal fees. 20. ...
Ruling
2002 Ruling 2002-0145983 - EMPLOYEE STOCK OPTION PLAN
Pursuant to the power granted it under paragraph XXXXXXXXXX of the Plan, as described in 15 above, the Board proposes to amend the first sentence of paragraph XXXXXXXXXX of the Plan as described in 12 above, by deleting the words ", other than a holder that is subject to tax under the Income Tax Act (Canada) in respect of such SAR," as well as the word "may" where it currently appears before "require", so that the sentence would read as follows: "The Board may, in its discretion at the time of grant or at any time thereafter, upon the exercise of an SAR, require a holder electing to exercise an SAR to receive cash in lieu of Common Shares. ...
Ruling
2002 Ruling 2002-0138413 - INTEREST DEDUCTIBILITY FINANCING FEES
Position: 1. a) & b)- interest is deductible 1 c)- Opinion provided based on proposed legislation pursuant to 20.2. 2. ...
Technical Interpretation - Internal
23 October 2002 Internal T.I. 2002-0135797 - FOREIGN EXCHANGE LOSSES
In document # 9703377, we indicated that "for purposes of paragraph 20(1)(f) the principal amount under the terms of the CBL (Consumer Based Loan) is the total amount paid on maturity plus the total of all payments in satisfaction of principal paid over the life of the obligation. ...
Technical Interpretation - Internal
31 October 2002 Internal T.I. 2002-0142497 - FOREIGN EXCHANGE LOSSES
In document # 9703377, we indicated that "for purposes of paragraph 20(1)(f) the principal amount under the terms of the CBL (Consumer Based Loan) is the total amount paid on maturity plus the total of all payments in satisfaction of principal paid over the life of the obligation. ...
Ruling
2002 Ruling 2002-0161413 - Derivatives - Foreign property rules
Reasons: Similar to ruling # E 2001-0079143. XXXXXXXXXX 2002-016141 XXXXXXXXXX, 2002 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX, in which you requested an advance income tax ruling in respect of the income tax consequences arising from the proposed transactions described below. ...
Technical Interpretation - Internal
27 November 2002 Internal T.I. 2002-0140507 - FOREIGN EXCHANGE LOSS
In document # 9703377, we indicated that "for purposes of paragraph 20(1)(f) the principal amount under the terms of the CBL (Consumer Based Loan) is the total amount paid on maturity plus the total of all payments in satisfaction of principal paid over the life of the obligation. ...
Technical Interpretation - Internal
27 November 2002 Internal T.I. 2002-0140517 - FOREIGN EXCHANGE LOSS
In document # 9703377, we indicated that "for purposes of paragraph 20(1)(f) the principal amount under the terms of the CBL (Consumer Based Loan) is the total amount paid on maturity plus the total of all payments in satisfaction of principal paid over the life of the obligation. ...
Ruling
2002 Ruling 2002-0168603 - XXXXXXXXXX
The Pubco Notes will have a XXXXXXXXXX-year term and annual interest rate of approximately XXXXXXXXXX %, payable semi-annually. ...
Ruling
2002 Ruling 2002-0177133 - LOSS UTILIZATION
B Co's audited consolidated financial statements for the year ended XXXXXXXXXX indicate that B Co had, on a consolidated basis: Long-term debt of approximately $ XXXXXXXXXX; A weighted average rate of borrowing on the long-term debt of XXXXXXXXXX%; Shareholders' equity of approximately $XXXXXXXXXX; and Short-term notes payable of approximately $XXXXXXXXXX. ...