Search - 阿里拍卖 司法拍卖

W Trust is XXXXXXXXXX; (p) "paid-up capital" has the meaning assigned by subsection 89(1); (q) "Parentco-Y" is a corporation more fully described in paragraph 18 hereof; (r) "Parentco-Z" is a corporation more fully described in paragraph 24 hereof; (s) "private corporation" has the meaning assigned by subsections 89(1) and 248(1); (t) "proceeds of disposition" has the meaning assigned by section 54; (u) "Securities Y" and "Securities Z" means the publicly-traded stock and the shares in the capital of the private corporation(s) owned by Target-Y and by Target-Z, respectively, as more particularly described in paragraphs 12 and 16 below; (v) "series of transactions or events" includes the transactions or events referred to in subsection 248(10); (w) "specified person" has the meaning assigned by paragraph 88(1)(c.2); (x) "Stated Capital" has the meaning given that term for the purposes of the BCA; (y) "subsidiary wholly-owned corporation" has the meaning assigned by subsection 248(1); (z) " substituted property" includes the meanings assigned by subsection 248(5) and paragraph 88(1)(c.3); (aa) "Target-Y" means "XXXXXXXXXX", a corporation more fully described in paragraphs 9 through 12 below, whose business address is XXXXXXXXXX; (ab) "Target-Z" means "XXXXXXXXXX", a corporation more fully described in paragraphs 13 through 16 below, whose business address is XXXXXXXXXX; (ac) "taxable Canadian corporation" has the meaning assigned by subsections 89(1) and 248(1); (ad) "Y" means XXXXXXXXXX, an adult child of Mrs. ... The issued share capital of Target-Z is held as follows: Shareholder Number Class paid-up capital ACB Estate XXXXXXX First Preferred $XXXXXXXX $ XXXXXX Estate XXXXXXX Second Preferred $ XXXXXXX $ XXXXXX Mrs. W Trust XXXXXXX Fourth Preferred $ XXXXXXX $ XXXXXX Z Trust XXXXXXX Common $ XXXXXXXX $ XXXXXX 15. ...

16 November 1990 Ruling 900401 F- Lump Sum Payment upon Death of a Partner to Estate Unedited CRA Tags 96(1.1), 53(1)(e)(iii) 24(1) 900401   A.Y. ... C)     In many circumstances partnerships will purchase life insurance on the partners to fund any required payments in the event of the death of the partner before retirement. ... 2)     Would such a payment be deductible in computing the income of the remaining partners even though it was funded by life insurance proceeds which were received tax-free? ...

19 June 1989 Ruling 73863 F- Qualified Farm Property Unedited CRA Tags 45, 110.6(1) qualified farm property 19(1) File No. 7-3863   G. ... Your enquiry relates to the following hypothetical fact situation: 1)     A taxpayer has farmed his property for over 20 years, the farm being his only source of income. 2)     On January 1, 1990, the taxpayer registers a plan of subdivision on the farm land with the intention of servicing the subdivided lots, constructing houses on them, and selling them. 3)     On December 31, 1992 the taxpayer sells all the lots and houses.  It is your view that: 1)     On January 1, 1990, the taxpayer would have a notional capital gain on the farm property upon the conversion of the property from farming to development use.  ...

19 January 1990 Ruling HBW4125M1/6591M1 (E) F- Exchange of Information Agreement Unedited CRA Tags n/a   January 19, 1990 TAXATION PROGRAMS BRANCH Provincial and International   Relations Division Mr. ... Senécal Assistant Deputy Minister 957-2072 HBW 4125-M1   HBW 6591-M1 24(1) We enclose for your information copy of the exchange of information agreement which was negotiated this week between officials of the Canadian and 24(1) As Provincial and International Relations Division represented the Department at the negotiating sessions, we would be pleased to answer any questions you might have. ...

5 December 1990 Ruling F3973 F- In-house Loss Utilization Unedited CRA Tags n/a   December 5, 1990 Director Current Amendments and Special Audits Division Regulations Division   W.R. McColm Attention: Sharon Gulliver 957-2068 Tax Avoidance Section   F-3973 In-House Loss Utilization This is in reply to your memorandum of November 5, 1990 concerning the above subject matter. ... D'AurelioDirectorCurrent Amendments and Regulations Division c.c.      ...

24 August 1990 Ruling 74783 F- Roll-over of Shares of Family Farm Corporation- Application of "GAAR" where Immediate Disposition Unedited CRA Tags 55(1) permitted redemption, 56(2), 73(4), 73(5), 110.6(2)   August 24, 1990 Special Audits Division Rulings Directorate J.G. ... Teixeira   957-2119   7-4783 Re: 1989 ROUND TABLE QUESTION NO. 43 We are writing in response to your memorandum dated March 2, 1990, in which you requested our comments regarding the scope of the answer to question No. 43 in the 1989 Canadian Tax Foundation Round Table and an actual reassessing situation. ...

6 April 1990 Ruling 59751 F- Retiring Allowance, Legal Fees and Interest Unedited CRA Tags 6(3), 56(1)(a)(ii) 19(1) File No. 5-9751   W.C. ... While we cannot, at this time, provide a ruling, we can offer the following comments. a.      ... Again an exact determination may only be made on the basis of an analysis of all relevant facts. c.      ...

Le capital-actions autorisé de Comco est composé d'un nombre illimité d'actions ordinaires d'une valeur nominale de XXXXXXXXXX $ chacune. 6. ... Senco déclarera en faveur de son actionnaire RPA, un dividende de XXXXXXXXXX $ payable par la remise des actions de Senco II acquises en 12 et 13 ci-haut et du billet de XXXXXXXXXX $ émis au paragraphe précédent. 15. RPA disposera de la totalité des actions de Senco en faveur de Comco pour une considération de XXXXXXXXXX $. ...

18 December 1990 Ruling 902881 F- Deductibility of Expenditures of Engineering Business Unedited CRA Tags 20(10) 19(1) 902881   M. Eisner   (613) 957-2138 December 18, 1990 19(1) This is in reply to your letter of October 17, 1990 concerning the deductibility of certain expenditures for income tax purposes. ...

21 September 1990 Ruling 900203 F- Exchange of Shares in the Course of Corporate Reorganization Unedited CRA Tags 7(1.5), 7(1.1), 85.1(1), 87, 110(1)(d.1) 24(1) 900203   R.D. Weil   (613) 957-2141 19(1) EACC9627 September 21, 1990 Dear Sirs: Re: Subsection 7(1.5) of the Income Tax Act This is further to our letter to you of May 28, 1990 concerning the interpretation of subsection 7(1.5) of the Act in the following situation. ...