Search - 阿里拍卖 司法拍卖

.), as amended to the date hereof, and unless otherwise stated, every reference herein to a part, division, subdivision, section, subsection, paragraph, subparagraph or clause is a reference to the corresponding provision of the Act; (b) “AmalCo” means the corporation, to be formed by the merger of ProfitCo and LossCo as described in Paragraph 20, which will be a taxable Canadian corporation XXXXXXXXXX; (c) “AmalCo XXXXXXXXXX Services” means the ProfitCo XXXXXXXXXX Services to be provided by AmalCo to former ProfitCo and LossCo XXXXXXXXXX and customers as described in Paragraphs 23 to 26; (d) “Amalgamation” means the amalgamation of LossCo and ProfitCo to form AmalCo, as described in Paragraph 20; (e) XXXXXXXXXX; (f) XXXXXXXXXX; (g) “CRA” means the Canada Revenue Agency; (h) XXXXXXXXXX has the meaning assigned by subsection XXXXXXXXXX; (i) “Excluded Branches” means up to XXXXXXXXXX LossCo Branches that AmalCo intends to sell or otherwise transfer referred to in Paragraph 26; (j) “LossCo” means XXXXXXXXXX, a taxable Canadian corporation XXXXXXXXXX; (k) “LossCo XXXXXXXXXX ” means the XXXXXXXXXX that were operated by LossCo in XXXXXXXXXX (including XXXXXXXXXX which are operated pursuant to an agreement with XXXXXXXXXX) that, as described in Paragraph 14, were disposed of prior to the date of the Amalgamation (l) “LossCo Branches” means all XXXXXXXXXX operated in XXXXXXXXXX by LossCo as described in Paragraph 7, but for greater certainty not the XXXXXXXXXX LossCo XXXXXXXXXX; (m) “LossCo Consolidated Branches” means up to four LossCo Branches that AmalCo intends to close as described in Paragraph 25; (n) “LossCo Continuing Branches” means XXXXXXXXXX LossCo Branches operated by LossCo that are to be operated by AmalCo in their current form and any Excluded Branches and LossCo Consolidated Branches that ProfitCo continues to operate; (o) “LossCo XXXXXXXXXX Services” means the services described in Paragraph 7; (p) “LossCo Group” means the group of XXXXXXXXXX that operate using the XXXXXXXXXX trade name, that was primarily developed through business operations in XXXXXXXXXX, which includes LossCo, LossCo Lender and LossCo Shareholder; (q) “LossCo Shareholder” means XXXXXXXXXX; (r) “LossCo Lender” means XXXXXXXXXX; (s) “Paragraph” means a numbered paragraph in this advance income tax ruling; (t) “ProfitCo” means XXXXXXXXXX, a taxable Canadian corporation and a XXXXXXXXXX; (u) “ProfitCo Branches” means the XXXXXXXXXX ProfitCo operates throughout XXXXXXXXXX; (v) “ProfitCo XXXXXXXXXX” means the services described in Paragraph 2; (w) “Subject Transactions” means the transactions described in Paragraphs 14 to 28; and (x) “taxable Canadian corporation” has the meaning assigned by subsection 89(1). ... The XXXXXXXXXX LossCo XXXXXXXXXX employ XXXXXXXXXX of XXXXXXXXXX LossCo employees and have accepted less than XXXXXXXXXX % of LossCo’s deposits and hold less than XXXXXXXXXX % of LossCo’s loan assets. 9. ... Projections indicate that AmalCo will retain as XXXXXXXXXX customers XXXXXXXXXX of the XXXXXXXXXX estimated Lossco XXXXXXXXXX customers (XXXXXXXXXX %), will retain $XXXXXXXXXX of $XXXXXXXXXX of LossCo’s deposit liabilities (XXXXXXXXXX %) and will retain $XXXXXXXXXX of LossCo’s $XXXXXXXXXX of loans (XXXXXXXXXX %). 28. ...

In XXXXXXXXXX, three rental properties located in XXXXXXXXXX ("property #4"), XXXXXXXXXX ("property #5") and XXXXXXXXXX ("property #6"), were owned as follows: Aco XXXXXXXXXX % Bco XXXXXXXXXX Pre-Cco XXXXXXXXXX XXXXXXXXXX % Each percentage represents an undivided interest in the properties. 18. ... The share capital of Opco includes: Authorized: (Unlimited number of Class A Preferred shares, XXXXXXXXXX % non-cumulative, voting, and redeemable. (Unlimited number of Class B Preferred shares, variable, XXXXXXXXXX % noncumulative, non-voting, and redeemable. * Unlimited number of Class C Preferred shares, variable, XXXXXXXXXX % non-cumulative, non-voting, and redeemable. ...

Canco2 directly owns XXXXXXXXXX % of the common shares of FAl while NR1 directly owns XXXXXXXXXX % of the convertible preferred shares of FAl. ... FAl directly owns XXXXXXXXXX % of the Class B common shares of FA2 while Foreign Parent directly owns XXXXXXXXXX % of the Class A common shares and XXXXXXXXXX % of the preferred shares of FA2. ... Initially, the interest rate is expected to be approximately XXXXXXXXXX %. ...

S Corp's interest in Partnership A entitles it to XXXXXXXXXX % of the income and distributable assets of Partnership A. The Investors own the remaining XXXXXXXXXX % interest in Partnership A. ... Partnership A owns the remaining XXXXXXXXXX % interest in Partnership B. ...

La juste valeur marchande (la "JVM") estimative de l'ensemble des Actions A est de XXXXXXXXXX $. ... Le PBR, le capital versé et la JVM de l'ensemble des Actions B sont de XXXXXXXXXX $. ... Le PBR de l'ensemble des Actions C est de XXXXXXXXXX $, alors que leur JVM est d'environ XXXXXXXXXX $. ...

Can capital gains be paid out of the trust & then subsequently out of the fund by promissory note ("PN")? ... Prior to the amendments described in paragraph 39, the partnership agreement governing LP2 provided that LP2 will distribute to holders of the LP2 Units XXXXXXXXXX % of LP2 Distributable Cash at any time during the fiscal year and XXXXXXXXXX % to the general partner. 22. ... Pursuant to the terms of such partnership agreement, Can SFE Corp has a XXXXXXXXXX % partnership interest, with the remaining XXXXXXXXXX % held by XXXXXXXXXX; and (l) XXXXXXXXXX % of the issued Topco Class B Shares were held by the Can SFE GP; 28. ...

XXXXXXXXXX 2012-045622 XXXXXXXXXX, 2012 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling – XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX in which you requested an advance income tax ruling on behalf of the above-noted taxpayers. ... As at XXXXXXXXXX, Holdco had the following tax attributes: • CDA: XXXXXXXXXX approximately XXXXXXXXXX. • GRIP: approximately XXXXXXXXXX. 14. ...

(g) The Producer will retain XXXXXXXXXX rights to the Picture and share in up to XXXXXXXXXX percent (XXXXXXXXXX %) of the net revenues earned by the Picture XXXXXXXXXX. ... Investors will have the option but will not be required to finance approximately XXXXXXXXXX % of the purchase price of their Class A Units by way of an Investor Loan. 26. ... As described in paragraph 4 of Interpretation Bulletin IT-477 (Consolidated) — Capital Cost Allowance — Patents, Franchises, Concessions and Licences, while it is the CRA’s general position that deductions for the capital cost of a class 14 property should be made equally over the remaining life of the property, some other basis of deduction may be appropriate. ...

The Auction Tender Limit Number is the number determined by the following formula: Auction Tender Limit Number = X(1- Y/Z) where: X = the total number of XXXXXXXXXX Common Shares which XXXXXXXXXX offers to repurchase under the Offer Y = the number of XXXXXXXXXX Common Shares tendered pursuant to Proportionate Tenders Z = the total number of XXXXXXXXXX Common Shares outstanding prior to the Offer If the number of XXXXXXXXXX Common Shares tendered by Auction Tenders at or below the Purchase Price is less than or equal to the Auction Tender Limit Number, XXXXXXXXXX will repurchase at the Purchase Price all XXXXXXXXXX Common Shares tendered pursuant to Auction Tenders. ... Assuming no odd lot holders or adjustments with respect to fractional shares, XXXXXXXXXX Common Shares would be repurchased at $XXXXXXXXXX as follows: • holders who tendered XXXXXXXXXX Common Shares at prices less than or equal to the Purchase Price will have their shares so tendered purchased in the following ratio XXXXXXXXXX XXXXXXXXXX • holders who tendered XXXXXXXXXX Common Shares by way of Proportionate Tender would have XXXXXXXXXX% of such shares repurchased (XXXXXXXXXX total shares). ...

Foreign Parent owns XXXXXXXXXX % of Foreign Holdco. 3. Foreign Holdco is a XXXXXXXXXX limited liability company which owns XXXXXXXXXX % of Holdco. 4. ... Opco owns all the common shares of Canco 1, which also has a XXXXXXXXXX year end, and a XXXXXXXXXX % partnership interest in GP. 9. Canco 2 owns XXXXXXXXXX class A preferred shares of Canco 1 and a XXXXXXXXXX % partnership interest in GP as capital property. 10. ...