Search - 2002年 抽纸品牌 质量排名

Partnership B does not have material property other than shares of Holdco (approximately XXXXXXXXXX % of the issued and outstanding shares of Holdco), various inter-entity receivables owing by entities in the DC Group and an interest in XXXXXXXXXX. ... In addition to its partnership interests in Partnership B and Partnership C, Subco B owns a XXXXXXXXXX partnership interest (approximately XXXXXXXXXX %) in Partnership F. 30. ... The above rulings are given subject to the limitations and qualifications set out in Information Circular 70-6R5 dated May 17, 2002 and are binding on the CRA provided that the Proposed Transactions are completed before XXXXXXXXXX. ...

Partnership B did not have material property other than shares of Holdco (approximately XXXXXXXXXX % of the issued and outstanding shares of Holdco), various inter-entity receivables owing by entities in the DC Group and an interest in XXXXXXXXXX. ... In addition to its partnership interests in Partnership B and Partnership C, before the winding-up of Subco B, Subco B owned a XXXXXXXXXX partnership interest (approximately XXXXXXXXXX %) in Partnership F. 30. ... The above rulings are given subject to the limitations and qualifications set out in Information Circular 70-6R5 dated May 17, 2002 and are binding on the CRA provided that the Proposed Transactions are completed before XXXXXXXXXX. ...

Foreign PubCo is widely held, and, to the best of Foreign PubCo's knowledge, at XXXXXXXXXX, the only shareholder owning more than XXXXXXXXXX% of the ordinary shares of Foreign PubCo is Shareholder A – XXXXXXXXXX%. 7. ... The aggregate FMV, immediately before the transfer of property by DC to TC described in Paragraph 92, of the common shares of Foreign SpinCo owned by ForCo 2 will be equal to or approximate the amount determined by the formula, on the assumption that ForCo 2 is the participant, DC is the distributing corporation and Foreign SpinCo is the acquiror, (A × B/C) + D as found in subparagraph (b)(iii) of the definition of "permitted exchange" in subsection 55(1). 88. ... Our rulings are given subject to the limitations set out in Information Circular 70-6R5 dated May 17, 2002, and are binding on the CRA provided the Proposed Transactions are completed within six months of the date of this letter. ...

The aggregate FMV, immediately before the transfer of the Newco Common Shares by Canco to Tco described in Paragraph 44, of the Foreign Spinco membership interests owned by Foreign Pubco will be equal to or approximate the amount determined by the formula, on the assumption that Foreign Pubco is the participant, Canco is the distributing corporation and Foreign Spinco is the acquiror, (A x B/C) + D as found in subparagraph (b)(iii) of the definition of "permitted exchange" in subsection 55(1). 33. ... These rulings are given subject to the limitations and qualifications set out in Information Circular 70-6R5 issued by CRA on May 17, 2002 and are binding on the CRA provided that the Proposed Transactions (XXXXXXXXXX and the transactions described in paragraphs 48 and 49 which do not take place before the Spin-Out) are completed by XXXXXXXXXX. ...

DC has estimated its tax accounts as of XXXXXXXXXX as follows: (a) RDTOH – $XXXXXXXXXX (b) GRIP- $XXXXXXXXXX (c) CDA- $XXXXXXXXXX (d) pre-1972 CSOH- $XXXXXXXXXX Specifically, DC will not have any CDA or pre-1972 CSOH balance immediately before the Proposed Transactions. ... The above rulings are given subject to the limitations and qualifications set out in Information Circular 70-6R5 dated May 17, 2002 and are binding on the CRA provided that the Proposed Transactions (other than the filing of articles of dissolution of DC as described in Paragraph 57) are completed before XXXXXXXXXX. ...

Immediately before the transfer of the Newco Common Shares by DC to TC as described in Paragraph 80, the aggregate FMV of the Foreign Spinco Parent common shares owned by Foreign Pubco will be equal to or approximate the amount determined by the formula, on the assumption that Foreign Pubco is the participant, DC is the distributing corporation, Foreign Spinco Parent is the acquiror and the distribution is the transfer of Newco Common Shares described in Paragraph 80, (A x B/C) + D As found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1). 72. ... The above rulings are given subject to the limitations and qualifications set out in Information Circular 70-6R5 dated May 17, 2002 and are binding on the CRA provided that the Proposed Transactions are completed before XXXXXXXXXX. ...

Prior to entering into the Proposed Transactions, the issued and outstanding shares of the capital stock of DC, which represent Capital Property to its shareholders, will be held as follows: Shareholder # Common Shares PUC ACB FMV SCo XXXXX $XXXXX $XXXXX $XXXXX WCo XXXXX $XXXXX $XXXXX $XXXXX 4. ... These rulings are given subject to the limitations and qualifications set forth in Information Circular 70-6R5 issued on May 17, 2002, and are binding on the CRA, provided that the Proposed Transactions are completed within six months of the date of this letter. ...

Since the amount of total gifts for the taxation year of an individual in the year the individual dies is not limited to XXXXXXXXXX % of the individual's income for the year, Individual A's estate could have donated property to a qualified donee to fully offset any capital gains tax liability otherwise payable in respect of the year of Individual A's death. 45. ... These rulings are given subject to the limitations and qualifications set forth in Information Circular 70-6R5 issued on May 17, 2002, and are binding on the CRA provided that the undertakings described in paragraph 3 of the COMMENTS below are fulfilled. ...

During XXXXXXXXXX lifetime, XXXXXXXXXX will own XXXXXXXXXX common shares of Trustco, which will represent XXXXXXXXXX % of the issued shares of Trustco. 28. ... These rulings are given subject to the limitations and qualifications set forth in Information Circular 70-6R5 issued on May 17, 2002, and are binding on the Canada Revenue Agency provided that the proposed transactions are completed before XXXXXXXXXX and the undertakings described in paragraph 2 of the COMMENTS below are fulfilled. ...

Immediately after this share exchange, the FMV of each Participant's share of the capital stock of Spinco will approximate the amount determined by the formula (A x B/C) + D as set out in subparagraph (b)(iii) of the definition "permitted exchange" in subsection 55(1). ... The above Rulings are subject to the limitations and qualifications set out in Information Circular 70-6R5 dated May 17, 2002 and are binding on CRA provided that the Proposed Transactions are completed by XXXXXXXXXX. ...