Search - 阿里拍卖 司法拍卖

The amount of the Final Settlement will be divided as follows: Description Taxpayers Principal Interest Total (a) Investments Claimant 1 XXXXXX XXXXX XXXXXX (b) RRSP Claimant 2 XXXXXX XXXXX XXXXXX (c) Loan- settlement Claimant 4 XXXXXX XXXXX XXXXXX (d) Bank accounts- replacement Claimant 5 (Business Account) XXXXXX XXXXX XXXXXX (e) Duplicate cheques- replacement Claimant 2 & Claimant 3 XXXXXX XXXXX XXXXXX (f) Duplicate cheques- replacement Claimant 5 (Trust Account) XXXXXX XXXXX XXXXXX (g) Reimbursement of various expenses Claimant 2, Claimant 3 & Claimant 5 XXXXXX XXXXXX Subtotal XXXXXX XXXXX XXXXXX (h) Damages Claimant 2, Claimant 3 & Claimant 5 XXXXXX Total estimated amount of the Final Settlement $XXXXX 8. ...

You describe the hypothetical situation as follows: 1.     U.S.Co. is a corporation incorporated in and a resident of the United State. 2.     U.S.Co. does not currently carry on business in Canada or have a permanent establishment in Canada within the meaning of Article V of the Canada-V.S. 1980 Tax Convention (the Convention). 3.      ...

La première série de transferts prévoira les transferts par OPCO de XXXXXXXXXX $ à GESTCO1 et de XXXXXXXXXX $ à NOUCO. ... Biens transférés par OPCO Plus particulièrement, OPCO transférera à chacune de GESTCO1 et NOUCO dans le cadre de la troisième série de transferts: (a) un intérêt indivis d'un taux (ci-après, "Proportion B") correspondant à 50 % moins la Proportion A, de ses terrains et biens amortissables (équipements, ordinateur et bâtiments), (b) un intérêt indivis de 50 % de tous les biens possédés par OPCO autres que son encaisse, ses terrains et biens amortissables (équipements, ordinateur et bâtiments), et (c) montant d'argent correspondant à 50 % du solde de son encaisse. ... (ci-après, "Considération FNLR2") d'un montant qui correspondra à 50 % des Frais nets de location reportés immédiatement avant le moment de l'attribution. ...

These shares represent XXXXXXXXXX % of the issued and outstanding shares of GP. ... DC’s LP Units comprise a XXXXXXXXXX % ownership in LP and entitle it to XXXXXXXXXX % of the net income and net losses of LP. The remaining XXXXXXXXXX % of LP is owned by the XXXXXXXXXX (“Partner”). ...

., a corporation existing under the laws of Canada; XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX "Fco Notes" means the unsecured, subordinated promissory notes issued by Fco XXXXXXXXXX, which, XXXXXXXXXX, are held by MFT, and includes any notes issued in exchange or substitution for such notes; "FMV" means fair market value, being the highest price available in an open and unrestricted market between informed prudent parties acting at arm's length and without compulsion to act, expressed in term of cash; XXXXXXXXXX "Gco" means XXXXXXXXXX, a corporation existing pursuant to the laws of the Province of XXXXXXXXXX; "ineligible property" has the meaning assigned by paragraph 88(1)(c); XXXXXXXXXX "MFT" means XXXXXXXXXX trust existing under the laws of the Province of XXXXXXXXXX; XXXXXXXXXX "I #1" means the XXXXXXXXXX created pursuant to the I #1 Agreement, pursuant to which Partnership #1 XXXXXXXXXX on certain incremental XXXXXXXXXX from the Target Assets #1, all as set forth in the I #1 Agreement; "I #1 Agreement " means the agreement entered into between Partnership #1 and N effective on Closing Date #1, creating I #1; "I #2" means the XXXXXXXXXX created under the I #2 Agreement, pursuant to which Partnership #2 granted Bco a XXXXXXXXXX on certain incremental XXXXXXXXXX from the Partnership #2 Assets, all as set forth in the I #2 Agreement; "I #2 Agreement" means the agreement entered into between Partnership #2 and Bco effective on Closing Date #2, creating I #2; XXXXXXXXXX "NSUB" means XXXXXXXXXX, a corporation formed pursuant to the laws of the Province of XXXXXXXXXX; "NSUB Shares" means the common shares of NSUB issued to N in exchange for XXXXXXXXXX; "N" means XXXXXXXXXX, a corporation formed pursuant to the laws of the Province of XXXXXXXXXX. ... It files its corporate income tax returns at the XXXXXXXXXX Taxation Centre and deals with the XXXXXXXXXX Tax Services Office; "P #2 Note" means a subordinated, unsecured promissory note issued by P #2 to Aco, and "P #2 Notes" refers to more than one P #2 Note; "paid-up capital" ("PUC") has the meaning assigned by subsection 89(1); "Partnership Act" means the Partnership Act (XXXXXXXXXX); "Partnership #1" means the XXXXXXXXXX, a XXXXXXXXXX partnership existing pursuant to the laws of the Province of XXXXXXXXXX; "Partnership #2" means the XXXXXXXXXX, a XXXXXXXXXX partnership existing pursuant to the laws of the Province of XXXXXXXXXX; "Partnership #2 Agreement" means the partnership agreement governing Partnership #2; "Partnership #2 Assets" means the XXXXXXXXXX contributed to Partnership #2, respectively; XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX "principal amount" has the meaning assigned by subsection 248(1); "private corporation" has the meaning assigned by subsection 89(1); "Proposed Transactions" means the proposed transactions described in Paragraphs 32 and 33; "public corporation" has the meaning assigned by subsection 89(1); "Put-Call Agreement #1" means the agreement dated XXXXXXXXXX pursuant to which SubTrust has the right to acquire, and P #1 has the right to dispose of, XXXXXXXXXX; "Put-Call Agreement #2" means the agreement dated XXXXXXXXXX pursuant to which SubTrust has the right to acquire, and P #2 has the right to dispose of, XXXXXXXXXX; "Regulations" means the Income Tax Regulations promulgated under the Act; "related persons" has the meaning assigned by subsection 251(2); "Resident" means a person or partnership that is not a Non-Resident and "Residents" refers to more than one Resident; "XXXXXXXXXX Indenture" means the XXXXXXXXXX Indenture dated XXXXXXXXXX; "XXXXXXXXXX Interest" means XXXXXXXXXX; XXXXXXXXXX "SPA #1" means the Share Purchase Agreement dated XXXXXXXXXX between Vendor #1, P #1 and Aco providing for, among other things, the acquisition, by P #1, of the N Common Shares from Vendor #1 XXXXXXXXXX; "SPA #2" means the Share Purchase Agreement dated XXXXXXXXXX between Vendor #2, P #2 and Aco providing for, among other things, the acquisition of the Target Shares by P #2; "specified shareholder" has the meaning assigned by subparagraph 88(1)(c.2)(iii) and subsection 248(1); XXXXXXXXXX XXXXXXXXXX "stated capital" in respect of the share capital of a corporation has the meaning assigned by the statute by which the corporation is governed; "Subco #1" means XXXXXXXXXX., a subsidiary wholly-owned corporation of Aco, incorporated pursuant to the laws of the Province of XXXXXXXXXX; "Subco #1 Class A Preferred Shares" means the Subco #1 Class A preferred shares; "Subco #1 Class A Preferred Share Redemption Amount" means, per Subco #1 Class A Preferred Share, the amount obtained when the FMV of the I #1 is divided by XXXXXXXXXX; "Subco #1 Redemption Note" means the unsecured, subordinated promissory note issued by Subco #1 on the redemption of the XXXXXXXXXX Subco #1 Class A Preferred Shares which had a principal amount equal to the FMV of the XXXXXXXXXX Subco #1 Class A Preferred Shares redeemed by Subco #1; "Subco #2" means XXXXXXXXXX., a subsidiary wholly-owned corporation of Aco, incorporated pursuant to the laws of the Province of XXXXXXXXXX; "Subco #2 Class A Preferred Shares " means the Subco #2 Class A preferred shares; "Subco #2 Class A Preferred Share Redemption Amount" means, per Subco #2 Class A Preferred Share, the amount obtained when the FMV of the I #2 is divided by XXXXXXXXXX; "Subco #2 Redemption Note " means the unsecured, subordinated promissory note issued by Subco #2 on the redemption of the XXXXXXXXXX Subco #2 Class A Preferred Shares which had a principal amount equal to the FMV of the XXXXXXXXXX Subco #2 Class A Preferred Shares redeemed by Subco #2; "Subject Transactions" means the Target Assets #1 Transactions, the Bco Asset Transactions and the Cco Asset Transactions, all of which are described in Paragraphs 11 to 31; "SubTrust" means XXXXXXXXXX, a commercial trust existing pursuant to the laws of the Province of XXXXXXXXXX, the sole beneficiary of which is MFT, XXXXXXXXXX; "Target Assets #1" means all of the XXXXXXXXXX assets held by N XXXXXXXXXX; "Target Assets #2" means the Vendor #2's XXXXXXXXXX assets that XXXXXXXXXX; "Target Corporations" means, collectively, XXXXXXXXXX; "Target Shares" means all the issued and outstanding shares of XXXXXXXXXX; "taxable Canadian corporation" has the meaning assigned in subsection 89(1); "taxable dividend" has the meaning assigned by subsection 89(1); XXXXXXXXXX "Trust Indenture" means the XXXXXXXXXX Trust Indenture dated XXXXXXXXXX XXXXXXXXXX between Aco and the Trustee, as amended; "Trustee" means the trustee of MFT, XXXXXXXXXX; "Unit" means a trust unit in MFT and "Units" refers to more than one Unit; "Unitholders" means holders of at least one Unit; XXXXXXXXXX "US" means the United States of America; XXXXXXXXXX "Vendor #1" means XXXXXXXXXX, a general partnership existing pursuant to the laws of the Province of XXXXXXXXXX; and "Vendor #2" means XXXXXXXXXX. ... The MFT Unitholder base is approximately as follows: Non-Residents (XXXXXXXXXX) XXXXXXXXXX % Tax-deferred (e.g., RRSPs) XXXXXXXXXX % Taxable Canadians XXXXXXXXXX % Institutional XXXXXXXXXX % 100% 2. ...

the financial institution should thus issue T4's rather than T5's for that interest. 2.      ... With respect to your questions 5, 7 and 8 referred to above, we have the following comments: 4.      ... Any amount over contributed during the year by the employee will be refunded when his tax return for the year is assessed. 5.      ...

Le PBR et le CV des XXXXXXXXXX actions ordinaires émises et en circulation du capital-actions de PORTCO détenues par Mme D est de XXXXXXXXXX $ par action, soit un total de XXXXXXXXXX $. ... PORTCO déclarera et paiera en argent à ses actionnaires un dividende de XXXXXXXXXX $ sur les actions ordinaires. ... Chaque actionnaire recevra un dividende en capital de XXXXXXXXXX $. 22. ...

Holdco1 holds XXXXXXXXXX % of the issued and outstanding shares of Opco and Holdco2 holds the remaining XXXXXXXXXX % of the issued and outstanding shares of Opco. ... Upon incorporation, Holdco1 will acquire XXXXXXXXXX % of the shares to be issued by New Holdco and Holdco2 will acquire the remaining XXXXXXXXXX % of the shares to be issued by New Holdco. 11. ... Yours truly, for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

. $ exchange rate of $XXXXXXXXXX. 13. DC also owns XXXXXXXXXX non-participating voting Class C common shares (the "Investment Common Shares") of each of XXXXXXXXXX. ... As of the date hereof, DC has the following issued and outstanding shares owned by the following shareholders: Class Number Stated Capital Shareholder DC Class A Shares XXXXXXXXXX $XXXXXXXXXX SON DC Class B Shares XXXXXXXXXX $XXXXXXXXXX SON DC First Preferred Shares XXXXXXXXXX $ XXXXXXXXXX Corp XXXXXXXXXX $ XXXXXXXXXX FATHERCO XXXXXXXXXX $ XXXXXXXXXX Cco XXXXXXXXXX $ XXXXXXXXXX SubA DC Second Preferred Shares XXXXXXXXXX $XXXXXXXXXX SubB 16. ... The ownership percentages of P2 are as follows: SubD XXXXXXXXXX% SubC XXXXXXXXXX % TOTAL 100.0% 40. ...

21 September 1989 Ruling 73763 F- Lease-option Agreements and IT-233R Unedited CRA Tags n/a   September 21, 1989 PUBLICATIONS DIVISION FINANCIAL INDUSTRIES Roy C. ... In the meantime, we suggest replacing paragraph 8 of the Bulletin by the following general comments: 8.     Under the typical arrangement described above, an investor would not be required to reduce his capital cost of the property by the amount of the limited-recourse liability under the notes or certificates. 9.      ...