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Ruling

2009 Ruling 2007-0251451R3 - Bituminous Sands Project

On XXXXXXXXXX, the Partners and their respective ownership interests in Partnership 1 were as follows: Corporation XXXXXXXXXX % SubCo XXXXXXXXXX % 4. ... The Partners and their respective ownership interests in Partnership 2 are as follows: Corporation XXXXXXXXXX % Partnership 1 XXXXXXXXXX % 5. ... SubCo owns XXXXXXXXXX % of the working interest in oil sands rights from the XXXXXXXXXX Group included on the Expansion Lands. ...
Ruling

2006 Ruling 2006-0180251R3 - Withholding Tax Exemption

(j) The Term Loans will bear interest at either (i) the Eurodollar Rate for the portion of Term Loan B or C that is a Eurodollar Loan; or (ii) the Base Rate for the portion of Term Loan B or C that is a Base Rate Loan plus, in each case, a margin (the "Applicable Term Margin") as set out below: Eurodollar Loan Base Rate Loan Initial Margin XXXXXX % XXXXXX % Leverage Ratio: >3.5x XXXXXX % XXXXXX % >3.0 but The Applicable Term Margins for the Term Loans will be decreased by XXXXXXXXXX if EBITDA during the most recent quarter for which financial statements have been delivered exceeds US$XXXXXXXXXX and will be increased by XXXXXXXXXX if EBITDA during the most recent quarter for which financial statements have been delivered is less than XXXXXXXXXX % of the EBITDA reflected in the Borrower's projections. ...
Ruling

2021 Ruling 2020-0874851R3 - Post-mortem Hybrid Pipeline

ERDTOH $XXXXXXXXXX; b. NERDTOH $XXXXXXXXXX; c. GRIP $XXXXXXXXXX; d. CDA the current balance is nil; however, the Corporation would have to realize net taxable capital gains in excess of approximately $XXXXXXXXXX in order for the CDA balance to be positive; and e. Net capital losses $XXXXXXXXXX. 8. Immediately before A’s time of death, the total accrued net capital gains on the Marketable Securities was approximately $XXXXXXXXXX. 9. ...
Ruling

30 November 1997 Ruling 9809643 F - EXCHANGEABLE DEBENTURES

La contrepartie totale payée par Acheteur pour les actions de Filiale sera donc d’environ XXXXXXXXXX $. ... La somme d’intérêt de XXXXXXXXXX $ représente XXXXXXXXXX % du montant de principal emprunté, soit XXXXXXXXXX $. ... A la suite de l’émission des débentures, Holdco recevra de ses détenteurs un montant de XXXXXXXXXX $. ...
Ruling

28 May 1991 Ruling 911281 F - Principal Residences

The four year limitation referred to above may be extended indefinitely if a)     the absence is the result of a relocation by the taxpayer's employer or spouse's employer, b)     neither the taxpayer nor the taxpayer's spouse is related to the employer, c)     the taxpayer returns to the original house while still employed by the same employer or before the end of the year following the year in which such employment terminates, and d)     the original house is located at least 40 kilometres farther than the temporary residence is from the new place of employment.   ...
Ruling

27 July 1990 Ruling 74731 F - Employees of a Country Other than Canada

27 July 1990 Ruling 74731 F- Employees of a Country Other than Canada Unedited CRA Tags 149(1)(a)   July 27, 1990 K. ... Arsenault Non-Resident Taxation Division 957-2126   7-4731 SUBJECT: Employees of a Country other than Canada This is in reply to your Memorandum dated February 16, 1990 whereby you requested our opinion as to whether the exemption from tax liability under Part I of the Act granted by paragraph 149(1)(a) of the Act applies to all types of income, including capital gains.  ...
Ruling

2011 Ruling 2010-0380601R3 - Ontario Apprenticeship Tax Training Credit

Dual Partner is the sole general partner of Limited Partnership B with a XXXXXXXXXX % interest in the partnership as a general partner and also owns a XXXXXXXXXX % limited partnership interest in Limited Partnership B. ... Therefore, immediately after the Conversion, the sole limited partner of Limited Partnership A will be Parentco, with a XXXXXXXXXX % partnership interest. Subco will remain the sole general partner of Limited Partnership A with a XXXXXXXXXX % partnership interest. 9. ...
Ruling

2014 Ruling 2013-0503611R3 - Post-Mortem Planning

Holdco has the following amounts in its tax accounts (estimated as of XXXXXXXXXX): RDTOH-$XXXXXXXXXX; GRIP – $XXXXXXXXXX; CDA- XXXXXXXXXX The tax consequences resulting from B's death 19. ... As of the date hereof, the issued and outstanding shares of the capital stock of Holdco are as follows: Shareholder Class Number of ACB PUC Redemption of shares shares held $ $ value$ Spousal Trust Class “A” XXX XXX XXX XXX Spousal Trust Class “B” XXX XXX XXX XXX Trust C Common XXX XXX XXX N/A Trust D Common XXX XXX XXX N/A Newco 24. ...
Ruling

2008 Ruling 2006-0217321R3 - Variation of a trust indenture

The quorum under the Existing Trust Declaration is XXXXXXXXXX Unitholders present in person or by proxy holding at least XXXXXXXXXX % of outstanding Units while the quorum under the Proposed Trust Declaration is XXXXXXXXXX Participants present in person or by proxy holding at least XXXXXXXXXX % of Units. ... For example, the following features of the Trust will not change under the Proposed Trust Declaration: (a) Trustee / Manager / Custodian: The Trustee, the Manager and the Custodian will remain respectively trustee, manager and custodian under the Proposed Trust Declaration as they are under the Existing Trust Declaration. (b) Unitholders / Participants: Pursuant to both the Existing Trust Declaration and the Proposed Trust Declaration, the beneficiaries of the Trust are the Unitholders / Participants. ...
Ruling

2008 Ruling 2007-0240271R3 - Purchase and bump

Target directly owned all the issued and outstanding shares of Subco 1, Subco 2, Subco 3, Subco 4, Subco 5, Subco 6 and XXXXXXXXXX % of the issued and outstanding shares of Sub 1. 8. Subco 1 owned: a. a XXXXXXXXXX % general partnership interest in GP 1; and b. a XXXXXXXXXX % general partnership interest in GP 2. 9. Subco 2 owned: a. the remaining XXXXXXXXXX % partnership interest in GP 1; b. the remaining XXXXXXXXXX % partnership interest in GP 2; c. all the issued and outstanding preferred shares of Sub 1A having a redemption value of $XXXXXXXXXX; and d. ...

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