Search - 2005年 抽纸品牌 质量排名
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Public Transaction Summary
Gastar -- summary under Outbound continuances
Its share price has declined from around $25 shortly after its incorporation at the end of 2005 to $2.50 currently. ... Gastar believes that it has incurred deficits in earnings and profits in each tax year beginning after 2005 except for the 2009 tax year. ... Holders – PFIC Gastar believes that it is not and never has been a PFIC. ...
Public Transaction Summary
Whiting/Kodiak -- summary under Canadian Buyco
Whiting/Kodiak-- summary under Canadian Buyco Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Cross-Border Acquisitions- Inbound- Canadian Buyco Acquisition of Kodiak Oil by Whiting acquisition subsidiary followed by survivor-style amalgamation Overview Kodiak, after being continued from the Yukon to B.C., will be acquired by Whiting Canadian Sub under a B.C. ... Kodiak does not believe it has been a PFIC at least since 2005. Arrangement It is a condition to the obligation of both Whiting and Kodiak to complete the arrangement that Whiting receive a written opinion from Foley & Lardner LLP, counsel to Whiting that for Code purposes the arrangement transactions should (i) be treated as a single integrated transaction for such purposes and (ii) qualify as a "reorganization" under ss. 368(1)(1)(A) and 368(1)(2)(E). Kodiak agreed to use commercially reasonable efforts to cause Dorsey & Whitney LLP, counsel to Kodiak, to deliver a similar opinion. ...
Public Transaction Summary
Sirius XM -- summary under Exchangeable Share Acquisitions
Sirius XM-- summary under Exchangeable Share Acquisitions Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Cross-Border Acquisitions- Inbound- Exchangeable Share Acquisitions exchangeable shares offered by Canadian-controlled purchaser (minority-owned by Sirius XM (Del.) sub) Overview A Delaware subsidiary (the “Guarantor”) of SIRI holds approximately a 37% equity interest in the “Company (some of it in the form of non-voting shares to address CRTC non-resident control issues) and two Canadian corporations (Slaight and Obelysk), together have approximately a 22.4% equity interest in the Company. ... On April 25, 2016, the Company received a demand letter from the Guarantor for an additional US$33.9 million as "activation fees" under one of the licences owed from 2005 to the end of January, 2016. ... Company ownership Principal Shareholder Type of Ownership Number of class A Shares assuming conversion of Class B and Class C Shares Percentage of Class A Shares Outstanding assuming conversion of Class B and Class C Shares Voting Interest represented by # of Voting Shares Percentage of Votes Obelysk Direct 12,982,135 10.09% 23,154,901 17.08% Guarantor Direct 47,324,180 36.77% 33,685,653 24.85% CBC Direct 13,056,787 10.15% 13,056,787 9.63% Slaight Direct 15,856,787 12.32% 26,170,361 19.31% Obelysk holds its interest in the form of 15,259,149 Class B Shares and 7,887,307 Class A Shares. ...
Public Transaction Summary
IMZ/Chaparral/Hochschild -- summary under Shares for Shares and Nominal Cash
IMZ/Chaparral/Hochschild-- summary under Shares for Shares and Nominal Cash Summary Under Tax Topics- Public Transactions- Spin-Offs & Distributions- S. 86 spin-offs- Shares for Shares and Nominal Cash Spin-off by IMZ of Chaparral Gold in a s. 86 reorg, and acquisition of IMZ by Hochschild Overview HOC, which is listed in the U.K. and headquartered in Peru, is interested in the 40% minority interest of IMZ in their Peruvian mining and development joint venture company, but not in IMZ's Nevada and Ecuadorian development properties (held through non-resident subsidiaries). ... It believes it was a PFIC for its 2005 to 2007 tax years. It expects Chaparral Gold to be a PFIC for its current tax year and that it may be a PFIC for subsequent years. ...
Public Transaction Summary
Alignvest/Trilogy -- summary under Subscription
Alignvest/Trilogy-- summary under Subscription Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Cross-Border Acquisitions- Outbound- Subscription subscription by Alignvest (a Cdn SPAC) for a majority interest in Trilogy (a holding LLC for New Zealand and Bolivian Opcos) resulting in dual residence Overview Alignvest, which is a Canadian special purpose acquisition corporation listed on the TSX, is subject to a deadline of June 2017 to apply its 2015 IPO proceeds (mostly still held in escrow) to a qualifying acquisition. ... Each subscriber for a Class A Unit of the Corporation received 1 Class A Restricted Voting Share and ½ of a warrant (an “Alignvest Warrant”) with a C$11.50 exercise price and a five-year term. ... Trilogy Trilogy, which is a holding company formed under the laws of the State of Washington on November 21, 2005, currently provides communications services through its New Zealand and Bolivian operating subsidiaries, Two Degrees Mobile Limited (“2degrees”) and NuevaTel (PCS de Bolivia) S.A. ...