Search - 2005年 抽纸品牌 质量排名

LP1 and LP2 directly hold a total of approximately XXXXXXXXXX % of the common shares of OpCo. 14. ... X controls a number of taxable Canadian corporations that collectively hold approximately XXXXXXXXXX % of the issued and outstanding SVS. ... The management of Lossco and NewCo has concluded that the interest rate to be charged on the NewCo Demand Note will not exceed XXXXXXXXXX %. 27. ...

DC also has an interest of XXXXXXXXXX % in JV1 and a XXXXXXXXXX % interest in JV2. ... Approximately XXXXXXXXXX % of the Class "A" shares and XXXXXXXXXX % of the Class "B" shares of the capital stock of Investco A; b. ... Approximately XXXXXXXXXX % of the Class "A" common shares and XXXXXXXXXX % of the Class "B" shares of the capital stock of Investco C. ...

However, provided that paragraph 4801(a) of the Regulations is enacted in substantially the same form as proposed in the draft regulations released by the Department of Finance on July 18, 2005 and subject to the same conditions as set out in the ruling, it is our view that the amendment to paragraph 4801(a) of the Regulations would not affect the ruling given. XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

À titre indicatif, vous nous mentionnez que la juste valeur marchande de l'Œuvre serait de XXXXXXXXXX $. ... Pour les fins du paragraphe 248(32) proposé par les Propositions législatives concernant l'impôt sur le revenu du 18 juillet 2005 (les "Propositions"), le montant de l'avantage résultant du prêt de l'Œuvre sera établi par un expert reconnu en semblable matière en fonction de l'âge du Donateur et du montant de loyer normalement chargé pour des prêts similaires. ...

No. 211 of 2003, the European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations 2003 and The Investment Funds, Companies and Miscellaneous Act, 2005 (the "Regulations"). ... The Sub-Fund1 Units and the Sub-Fund2 Units will not have any voting rights except the right, on written notice signed by Unitholders holding XXXXXXXXXX % of the units of Sub-Fund1 and Sub-Fund2, to require the Manager to resign. ... Yours truly, for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

The market interest rate quoted by LossCo's lender for the month of XXXXXXXXXX, to a borrower with the similar borrowing capacity and credit rating as LossCo, is approximately XXXXXXXXXX %. ... The losses previously incurred and future losses are XXXXXXXXXX % allocable to XXXXXXXXXX (XXXXXXXXXX). 6. ... The dividend rate will be equal to XXXXXXXXXX % plus the interest rate on Loan 2. 17. ...

Opco's income is expected to be approximately XXXXXXXXXX % allocable to XXXXXXXXXX, XXXXXXXXXX % to XXXXXXXXXX, XXXXXXXXXX % to XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX % in each of XXXXXXXXXX with nominal allocations to the remaining provinces. ... The dividend rate, expressed as a percentage of the amount for which a Newco Preferred Share was issued, will be equal to the sum of XXXXXXXXXX % plus the interest rate on Loan 2. 13. ... However, the Department of Finance has issued a letter dated April 21, 2005 (the "comfort letter"), indicating that it was prepared to recommend to the Minister of Finance that situations described in the comfort letter (i.e. essentially where a wholly-owned subsidiary is amalgamated with, or wound-up into, its parent) should not result in a significant increase in the interest of the subsidiary solely as a result of the application of paragraphs 55(3.01)(b) and (c). ...

., a company incorporated in Canada which carries out the Canadian operations of Bco; (e) "Common Contractual Fund or CCF" means a common contractual fund established by the Manager and authorised by the Financial Regulator under the Investment Funds, Companies and Miscellaneous Provisions Act 2005 (Ireland), as it may be amended, supplemented or consolidated from time to time, and meeting the conditions set out in Section 739I of the Taxes Consolidation Act (Ireland); (f) "CRA" means the Canada Revenue Agency; (g) "Custodian" means XXXXXXXXXX or any successor thereto approved by the Financial Regulator as custodian of the CCF and each Sub-Fund; (h) "Custody Agreement" means the agreement to be entered into between the Manager and the Custodian as amended, supplemented or otherwise modified from time to time in accordance with the requirements of the Financial Regulator; (i) "Deed of Constitution" means the deed of constitution to be entered into between the Manager and the Custodian providing for the constitution of the Fund; (j) "Financial Regulator" means the Irish Financial Services Regulatory Authority or any successor regulatory authority with responsibility for authorising and supervising the CCF; (k) "Fund" means the XXXXXXXXXX; (l) "Manager" means XXXXXXXXXX or any successor thereto duly appointed with the prior approval of the Financial Regulator as manager of the CCF and each Sub-Fund; (m) "Master Trust" means XXXXXXXXXX; (n) "Prospectus" means the prospectus prepared by the Manager and pursuant to which Unitholders acquire an investment in the Fund; (o) "Sub-custodian" means XXXXXXXXXX; (p) "Sub-Fund" or "Sub-Funds" means the Sub-Funds established in accordance with section XXXXXXXXXX of the Deed of Constitution by the Manager from time to time with the prior approval of the Financial Regulator; (q) "Tax Treaty" has the meaning assigned under subsection 248(1); (r) "TCA" means the Taxes Consolidation Act (Ireland), 1997 as amended; (s) "Unit" means a unit of account, representing a proportionate undivided co-ownership interest in the assets of a Sub-Fund as tenants in common with the other Unitholders of the Sub-Fund and includes any fraction of a Unit which may be further divided into different classes of Units. ... No. 211 of 2003 namely the European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations 2003 and The Investment Funds, Companies and Miscellaneous Act, 2005 (the "Regulations"). ... The Units will not have any voting rights (save the right, on written notice signed by Unitholders holding XXXXXXXXXX % of the Units, to require the Manager to resign). ...

.), as amended to the date hereof; (c) "active business" has the meaning assigned by subsection 95(1) of the Act; (d) "arm's length" has the meaning assigned by section 251 of the Act; (e) "B Co" means XXXXXXXXXX as described in 5 below; (f) "B Co Shares" means shares of B Co as described in 6 below; (g) "CBCA" means the Canada Business Corporations Act; (h) "CRA" means the Canada Revenue Agency; (i) "E Co" means XXXXXXXXXX as described in 5 below; (j) "E Co Leasing" means XXXXXXXXXX, a subsidiary of E Co Holdco as described in 5 below; (k) "E Co Holdco" means XXXXXXXXXX, a subsidiary of E Co as described in 5 below; (l) "fair market value" means the amount at which property would exchange hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of the relevant facts; (m) "Finance Co" means XXXXXXXXXX, a wholly-owned subsidiary of A Co; (n) "New B Co" means a newly incorporated company under the laws of XXXXXXXXXX as described in 14 below: (o) "New Canco" means a newly incorporated company as described in 13 below; (p) "New LP" means XXXXXXXXXX, Limited Partnership, a limited partnership as described in 8 below; (q) "Note" means a promissory note issued by A Co to W Co as described in 6 below; (r) "paid-up capital" has the meaning assigned by subsection 89(1) of the Act; (s) "Previous Ruling Request" means the taxpayer's written request for an advance income tax ruling dated XXXXXXXXXX, the taxpayer's letter dated XXXXXXXXXX, with additional information relating to the original request, and the Ruling (2005-015225) dated XXXXXXXXXX, 2005; (t) "principal amount" has the meaning assigned by subsection 248(1) of the Act; (u) "Proposed Transactions" means the proposed transactions described in 13 to 19 below; (v) "Regulations" means Income Tax Regulations, Consolidated Regulations of Canada, Chapter 945 as amended to the date hereof; (w) "related persons" has the meaning assigned by subsection 251(2) of the Act; (x) "taxable Canadian corporation" has the meaning assigned by subsection 89(1) of the Act; (y) "third parties" means persons who act at arm's length with the X Group; (z) "Transferred Shares" has the meaning described in 6 below; (aa) "Treaty" means the Canada-United States Income Tax Convention; (bb) "US LLC" means a newly formed limited liability company as described in 15 below; (cc) "W Co" means XXXXXXXXXX as described in 2 below; (dd) "X Co" means XXXXXXXXXX as described in 1 below; and, (ee) "X Group" means XXXXXXXXXX and entities related to it. ... The consideration provided by Finance Co was common shares of Finance Co with a fair market value equal to the fair market value of XXXXXXXXXX % of the B Co Shares. ...

LP1 and LP2 directly hold a total of approximately XXXXXXXXXX % of the common shares of OpCo. 14. ... The interest rate charged on the NewCo Demand Note was XXXXXXXXXX % per annum. 28. ... The interest rate to be charged on the US$ NewCo III Demand Note will not exceed XXXXXXXXXX % per annum. 50. ...