Search - 2005年 抽纸品牌 质量排名

2005 Ruling 2005-0134461R3- Loss utilization Unedited CRA Tags 112(1) Principal Issues: Loss utilization in a related group of companies. ... XXXXXXXXXX 2005-013446 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Advance Income Tax Ruling We are writing in response to your letter of XXXXXXXXXX wherein you requested certain changes to a previously issued advance income tax ruling on behalf of the above-referenced taxpayers (Ruling No. 2004-008854, dated XXXXXXXXXX, 2004). ... When issued, Lossco's Class A Preferred Shares will have an aggregate redemption amount equal to the principal amount of the Consolidated Note and rights and restrictions described as follows: (a) non-participating and non-voting; (b) entitled to a cumulative dividend, at a rate applied to the redemption amount of the shares of Prime plus XXXXXXXXXX %. ...

2005 Ruling 2005-0143711R3- Loss utilization in a related group of companies. ... XXXXXXXXXX 2005-014371 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: XXXXXXXXXX XXXXXXXXXX Advance Income Tax Ruling We are writing in response to your letter of XXXXXXXXXX wherein you requested an advance income tax ruling on behalf of the above-referenced taxpayers. ... The preferred shares will be: (a) non-participating and non-voting; (b) entitled to an annual cumulative dividend rate, applied to the redemption amount of the shares, described in Paragraph 12 below, equal to the interest rate applicable to the Profitco Demand Loan, described in Paragraph 11 below, plus XXXXXXXXXX %. ...

2005 Ruling 2005-0128301R3- Management Fee changes; new Classes of units MFT Unedited CRA Tags 104(7.1) 248(1) 9 Principal Issues: 1. ... XXXXXXXXXX 2005-012830 Attention: XXXXXXXXXX XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX in which you request an advance income tax ruling in respect of the above-noted taxpayer. ... XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch XXXXXXXXXX ...

2005 Ruling 2005-0125982R3- Purchase of Target and Bump Unedited CRA Tags 88(1)(c) 88(1)(d) 87(11) Principal Issues: Acquisition of control of a Target. ... XXXXXXXXXX 2005-012598 XXXXXXXXXX, 2005 Dear Sirs: Re: Advance Income Tax Ruling XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX in which you requested an advance income tax ruling on behalf of the above-noted taxpayers. ... Buyer GP has a XXXXXXXXXX % interest in Buyer LP. 11. Buyer Holdings operates as a holding company and its principal assets are the shares of the capital stock of Buyerco and advances made to Buyerco. ...

2005 Ruling 2005-0132891R3- In-house loss consolidation Unedited CRA Tags 20(1)(c) 55(3)(a) Principal Issues: Whether particular arrangement relating to utilization of non-capital losses within an affiliated group of companies is acceptable. ... The Newlossco3 Preferred Shares will be entitled to non-cumulative dividends not exceeding XXXXXXXXXX % of their redemption amount. ... The consideration will be a demand non-interest-bearing note (the " Newlossco2 Note B") with a principal amount and FMV equal to the redemption value of the Newlossco2 Preferred Share. ...

2005 Ruling 2004-0070981R3- Conversion to MFT Unedited CRA Tags 20(1)(c) XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX) Principal Issues: 1. ... XXXXXXXXXX 2004-007098 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request XXXXXXXXXX ("Opco") (XXXXXXXXXX) XXXXXXXXXX ("Sub 1") (XXXXXXXXXX) XXXXXXXXXX ("Sub 2") (XXXXXXXXXX) XXXXXXXXXX ("Sub 3") (XXXXXXXXXX) (collectively, the "Taxpayers") We are writing in response to your letter of XXXXXXXXXX in which you requested an advance income tax ruling on behalf of the Taxpayers and the Trust and AcquisitionCo, which are the entities that are to be created in connection with the Proposed Transactions described below. ... The members of the Partnership are Opco (as to an approximate XXXXXXXXXX% interest), Sub 1 (as to an approximate XXXXXXXXXX % interest), Sub 3 (as to an approximate XXXXXXXXXX% interest) and Sub 2 (as to an approximate XXXXXXXXXX% interest). ...

2005 Ruling 2005-0114861R3- Butterfly- XXXXXXXXXX Unedited CRA Tags 55(3)(b) 55(4) Principal Issues: Standard Butterfly Position: Favourable rulings given. ... XXXXXXXXXX 2005-011486 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: XXXXXXXXXX.- Paragraph 55(3)(b) Advance Income Tax Ruling Request This is in reply to your letter of XXXXXXXXXX, as modified by your other correspondence, wherein you requested an advance income tax ruling on behalf of the above-noted taxpayer. ... To date XXXXXXXXXX Class C Shares owned by Sibling2 have been transferred to Holdco and redeemed by DC pursuant to the Class C Redemption Agreement as follows: DC's Taxation Year # of Class C Shares Redeemed XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Subtotal XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Total XXXXXXXXXX None of the above-described redemptions of Class C Shares have taken place in contemplation of, or in connection with, the Proposed Transactions. ...

2005 Ruling 2005-0119891R3- 132.2- reorganization of a mutual fund trust Unedited CRA Tags 132.2 20(1)(c) 87 97(2) The following document was issued prior to the September 19, 2005 announcement that the provision of advance income tax rulings on income trusts and other flow-through entities would be postponed while the Department of Finance consultations are underway and until the government announces what action it may take. ... Position: In light of the July 18, 2005 proposed changes to 132.2, the use of that provision to achieve the proposed reorganization is acceptable in terms of policy. ... Subsection 96(1.01), as proposed by the July 18, 2005 Draft Amendments, will, if enacted, apply as follows. ...

2005 Ruling 2004-0104851R3- Single-wing Spilt-up Butterfly Unedited CRA Tags 55(3)(b) Principal Issues: Single-wing Split-up Butterfly- Mostly Standard Issues. ... XXXXXXXXXX 2004-010485 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: XXXXXXXXXX XXXXXXXXXX- Advance Income Tax Ruling Request This is in reply to your letter of XXXXXXXXXX, as modified by your other correspondence, wherein you requested an advance income tax ruling on behalf of the above-noted taxpayers. ... The issued and outstanding shares of DC are held as follows: Shareholder Number & Class of Shares Transferee1 XXXXXXXXXX Class A Shares Transferee1 XXXXXXXXXX Class C Shares Transferee2 XXXXXXXXXX Class C Shares Transferee1 XXXXXXXXXX Common Shares Transferee2 XXXXXXXXXX Common Shares Transferee1 controls DC by virtue of its XXXXXXXXXX Class A Shares and XXXXXXXXXX Common Shares. ...

2005 Ruling 2005-0111421R3- Sequential Spin-off Butterfly Reorganization Unedited CRA Tags 55(3)(b) Principal Issues: Sequential Spin-off Butterfly Reorganization- Several Issues. ... XXXXXXXXXX 2005-011142 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: RE: XXXXXXXXXX ("DC") XXXXXXXXXX ("DC Sub") Advance Income Tax Ruling Request This is in reply to your letter of XXXXXXXXXX, and your subsequent correspondence wherein you requested an advance income tax ruling on behalf of the above-noted taxpayers. ... 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. ...