Search - 2005年 抽纸品牌 质量排名

Holdco2 holds all of the "multiple voting shares" of the capital stock of Canco1, which entitle it to approximately XXXXXXXXXX % of the Canco1 shareholder votes. ... Before XXXXXXXXXX, Canco3 had XXXXXXXXXX common shares outstanding, of which approximately XXXXXXXXXX % were owned by A or corporations controlled by A and XXXXXXXXXX % were owned by current or former employees of Canco1. ... The Cancol Pref Shares have a fixed cumulative dividend of XXXXXXXXXX %, payable annually in U.S. dollars, and are redeemable by the holder on demand for an aggregate amount of USD $XXXXXXXXXX. ...

., c. 95, as amended; (bb) “Stock Exchange” means the XXXXXXXXXX; (cc) “Sub-Custodian” means XXXXXXXXXX; (dd) “Sub-Custodian’s Parent” means XXXXXXXXXX; (ee) “subsidiary wholly-owned corporation” has the meaning assigned by subsection 248(1) of the Act; (ff) “Tax Treaty” has the meaning assigned by subsection 248(1) of the Act; (gg) XXXXXXXXXX; (hh) “TLCA” means the Trust & Loans Companies Act (S.C. 1991, c. 45); (ii) “Unit(s)” means a unit of account, representing a proportionate undivided co-ownership interest in the assets of the Fund, as tenants in common with the other Unitholders. ... The executive partners own XXXXXXXXXX % of the Investment Manager with the remaining XXXXXXXXXX% owned by investors. ... A CCF is governed by The Investment Funds, Companies and Miscellaneous Act, 2005. ...

There is no person that beneficially owns more than XXXXXXXXXX % of the shares of Parent. 3. ... The non-capital losses of Parent carried forward from prior years are as follows: Year of origin Non-Capital Loss XXXXXXXXXX XXXXXXXXXX * estimate 5. ... The holders of preferred shares will be entitled to cumulative dividends, calculated daily by reference to the redemption/retraction price of the preferred shares at a rate equal to the sum of the interest rate on the Lossco Loan plus XXXXXXXXXX %. ...

A separate portfolio of assets owned by the CCF is not maintained for each class; f) "Common Contractual Fund" means a common contractual fund, constituted under the laws of Ireland, authorized by the Authority pursuant to Part 2 of the Investment Funds Act and meeting the conditions set out in Section 739I of the Foreign Tax Act; g) "CRA" means the Canada Revenue Agency; h) "Custodian" means XXXXXXXXXX, having its registered office at XXXXXXXXXX Ireland and acting as custodian with respect to the assets of the CCF; i) "Custodian Agreement" means the agreement between the Manager and the Custodian, dated XXXXXXXXXX, relating to the appointment and duties of the Custodian; j) "Deed of Constitution" means the deed of constitution dated XXXXXXXXXX, entered into between the Manager and the Custodian providing for the constitution of the CCF; k) "Designated Stock Exchanges" has the meaning assigned by section 262; l) "Foreign Tax Act" means Taxes Consolidation Act 1997 (Ireland), as amended; m) "Gross Income Payments" has the meaning assigned in subparagraph 8(f) below; n) "Investment" means a permitted investment set out in XXXXXXXXXX the Deed of Constitution; o) "Investment Funds Act" means Investment Funds, Companies and Miscellaneous Provision Act 2005 (Ireland), as amended; p) "Manager" means XXXXXXXXXX, having its registered office at XXXXXXXXXX Ireland, acting in its capacity as manager of the CCF as set out in the Deed of Constitution; q) "Mutual Fund Trust" has the meaning assigned by subsection 248(1); r) "New Investor" means an investor, resident of Canada or not, that qualifies to hold Units offered by the Prospectus and does not hold any Unit in the CCF as of the date of this ruling letter, but will subsequently invest in Units and for greater certainty, includes a resident of Canada only to the extent that the entity qualifies as exempt from tax pursuant to subsection 149(1); s) "Non-Resident" has the meaning assigned by subsection 248(1); t) "Prospectus" means the prospectus prepared by the Manager in accordance with the Investment Funds Act, the Deed of Constitution and the requirements of the Authority, and pursuant to which Unitholders acquire Units in the CCF; u) "Qualifying Investor" has the meaning assigned in the Deed of Constitution and generally means any institution (being an entity other than a natural person): which owns or invests on a discretionary basis at least XXXXXXXXXX (or its equivalent in another currency); or the beneficial owners of which are Qualifying Investors in their own right; v) "Register" means the register referred to in XXXXXXXXXX the Deed of Constitution; w) "Related Persons" has the meaning assigned by subsection 251(2); x) "Sub-Custodian" means the Canadian branch of XXXXXXXXXX, having its registered office at XXXXXXXXXX; y) "Taxpayer" has the meaning assigned by subsection 248(1); z) "Tax Treaty" means a tax treaty as defined in subsection 248(1); aa) "Unit" means an undivided co-ownership interest of Unitholders as tenants in common with the other Unitholders in the assets owned by a Common Contractual Fund or the CCF, as the case may be, which may be further divided into further classes of Units; and bb) "Unitholder" means any person holding a Unit and entered on the register of a Common Contractual Fund or the CCF as being the holder of a Unit such holder being legally entitled to an undivided co-ownership interest as tenants in common with the other holders in the assets owned by a Common Contractual Fund or the CCF, as the case may be. ... The Units of the CCF do 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). ... The CCF will not purchase more than XXXXXXXXXX % of the outstanding shares of any one issuer and will monitor its portfolio to ensure that its holdings do not exceed this XXXXXXXXXX % threshold. 19. ...

., a corporation incorporated under the XXXXXXXXXX that carries on business under the name 'XXXXXXXXXX '; (f) "Beneficiaries" means the residual beneficiaries of the Estate described in Paragraph 8; (g) "Canadian-controlled private corporation" or "CCPC" has the meaning assigned by subsection 125(7); (h) "capital property" has the meaning assigned by section 54; (i) "Cco" means XXXXXXXXXX., a corporation incorporated under the XXXXXXXXXX (j) "Child 1" means XXXXXXXXXX of X; (k) "Child 2" means XXXXXXXXXX of X; (l) "Child 3" means XXXXXXXXXX of X; (m) "Child Note" means a promissory note of Newco with a fair market value and face amount equal to XXXXXXXXXX of the adjusted cost base of the shares of Holdco to the Estate as determined under subsection 84.1(2) for the purposes of the transfer described in Paragraph 15. ... However, the Tax Legislation Division of the Department of Finance issued a comfort letter to our Directorate dated March 4, 2005 (the "Comfort Letter"). ...

Holdco holds XXXXXXXXXX % of the issued and outstanding common shares of Profitco XXXXXXXXXX. ... However, we understand that 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). ...

Ruling # 2005-011948, dated XXXXXXXXXX, 2005, was obtained in respect of the formation of Partnership in XXXXXXXXXX. 15. ...

Advance income tax ruling # 2005-011948, dated XXXXXXXXXX, 2005, was obtained from the CRA in respect of the formation of Partnership in XXXXXXXXXX. 15. ...

Opinion On July 18, 2005, the Department of Finance released legislative proposals concerning section 132.2. ... XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

2006 Ruling 2006-0191591R3- Sequential Butterfly Reorganization Unedited CRA Tags 55(3)(b) Principal Issues: Various Routine Issues- Changes in facts from ruling 2005-011142 that was issued June 14, 2005. XXXXXXXXXX 2006-019159 XXXXXXXXXX, 2006 Dear XXXXXXXXXX: RE: XXXXXXXXXX This is in reply to your email request on XXXXXXXXXX, wherein you requested certain changes to the advance income tax ruling that was issued to the above-noted taxpayers on XXXXXXXXXX, 2005 (our file number 2005-011142 and referred to in this letter as the "Previous Ruling"). ... The TC Special Shares will have the following terms and conditions: (a) each TC Special Share will be redeemable, subject to applicable law, at any time at the option of TC at a redemption amount equal to the aggregate FMV of the consideration for which such share was issued divided by the total number of issued TC Special Shares (plus any declared but unpaid dividends); (b) each TC Special Share will be retractable, subject to applicable law, at any time at the option of the holder at a retraction amount equal to the redemption amount described above; (c) the holder of each TC Special Share will be entitled to a non-cumulative XXXXXXXXXX % cash dividend as and when declared by the board of directors from time to time, which dividend need not also be declared on any other class of shares of TC; (d) there will be a provision restricting the payment of dividends on other classes of shares so that no such dividends may be paid on any other class of shares of TC if the resulting realizable value of the net assets of TC after payment of the dividends would be less than the aggregate of the redemption amounts of all of the TC Special Shares then outstanding; (e) the holder of each TC Special Share will be entitled, upon the liquidation, dissolution or winding-up of TC, to a payment in priority to all other classes of shares of TC ranking junior to the TC Special Shares of an amount equal to the redemption amount thereof to the extent of the amount or value of property available under applicable law for payment to shareholders upon dissolution, but will be entitled to no more than the amount of that payment; and (f) the holder of each TC Special Share will not be entitled to vote at meetings of shareholders of TC. 36. ...