Search - 2005年 抽纸品牌 质量排名

2005 Ruling 2005-0126111R3- Spin-off butterfly Unedited CRA Tags 55(3)(b) Principal Issues: Spin-off butterfly involving a public company- no types of property basis. ... XXXXXXXXXX 2005-012611 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: RE: XXXXXXXXXX- Advance Income Tax Ruling Request This is in reply to your letter of XXXXXXXXXX, as modified by your subsequent correspondence, wherein you requested an advance income tax ruling on behalf of the above-noted taxpayer. ... 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). ...

2005 Ruling 2005-0151921R3- Butterfly Distribution Unedited CRA Tags 55(3)(b) 40(3.4) Principal Issues: Butterfly distribution- two distributing corporations owned equally by the same shareholders. ... XXXXXXXXXX 2005-015192 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: 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 authorized share capital of each of the Sibling Holdcos will include a class of voting common shares (collectively referred to as "Sibling Holdco Common Shares") and four classes of non-voting, non-participating preferred shares share (each class of shares collectively referred to as "Sibling Holdco Class A Shares", "Sibling Holdco Class B Shares", "Sibling Holdco Class C Shares " and "Sibling Holdco Class D Shares", respectively), bearing a discretionary non-cumulative dividend of up to XXXXXXXXXX% per month and redeemable at the option of the corporation or shareholder for an amount equal to the fair market value of the amount received by the corporation as consideration for the issuance of such particular shares. 8. ...

Les terrains qui sont présentement détenus par XXXXXXXXXX lui furent transférés par XXXXXXXXXX le XXXXXXXXXX en échange d'un billet à demande de XXXXXXXXXX $ et de XXXXXXXXXX actions de catégorie "A". ... La société est autorisée à émettre des actions des catégories "A", "B", "C", "D", "E", "F", "G", "H", dont les caractéristiques sont exposées dans votre lettre du 19 décembre 2005. ... Le paragraphe 248(1) de la LIR définit une SEPE de la façon suivante (nous ne reprenons que les passages de cette définition qui sont pertinents en l'espèce): [...] société privée sous contrôle canadien et dont la totalité, ou presque, de la juste valeur marchande des éléments d'actifs est attribuable, à un moment donné, à des éléments qui sont: a) soit utilisés principalement dans une entreprise que la société [...] exploite activement principalement au Canada; [...] ...

The XXXXXXXXXX 2005 Ruling confirmed the continued application of certain of the rulings contained in our letter dated XXXXXXXXXX, 2004 (File number 2004-006027) as modified in two supplementary rulings dated XXXXXXXXXX, 2005 and XXXXXXXXXX, 2005 (collectively, the "Existing Ruling"), subject to statutory amendments enacted or court decisions rendered after December 22, 2005. ... Documents submitted in connection with the XXXXXXXXXX 2005 Ruling or the Existing Ruling may be part of this document only to the extent described therein, and only to the extent that the XXXXXXXXXX 2005 Ruling and the Existing Ruling are part of this document. ... Consequently, it is expected that XXXXXXXXXX % of the Newco Common Shares will be allocated to the Charity Portion and XXXXXXXXXX % of the Newco Common Shares will be allocated to the Society Portion. ...

A separate portfolio of properties held 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 and acting as custodian with respect to the properties 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 clause XXXXXXXXXX of 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, 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) at the moment of the investment in the CCF and afterwards; 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; v) "Register" means the register referred to in sub-clause XXXXXXXXXX of the Deed of Constitution; w) "Regulations" means Statutory Instrument No. 211 of 2003 – European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations 2003. x) "Related Persons" has the meaning assigned by subsection 251(2); y) "Sub-CanCustodian" means XXXXXXXXXX; z) "Taxpayer" has the meaning assigned by subsection 248(1); aa) "Tax Treaty" means a tax treaty as defined in subsection 248(1); bb) "Unit" means an undivided co-ownership interest of Unitholders as tenants in common with the other Unitholders in the properties held by a Common Contractual Fund or the CCF, as the case may be, which may be further divided into further classes of Units; and cc) "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 properties held by a Common Contractual Fund or the CCF, as the case may be. ... 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. 20. ...

Favourable rulings issued in XXXXXXXXXX 2004, XXXXXXXXXX 2005 and XXXXXXXXXX 2006 with respect to this particular issue. ... PBR " Ressource minérale " au sens du paragraphe 248(1). Ressource Minérale " Société publique " au sens du paragraphe 89(1). ... F 2004-0062881R3), le XXXXXXXXXX 2005 (no. F 2004-0149001R3) et le XXXXXXXXXX 2006 (no. ...

Following the amalgamation, XXXXXXXXXX % of the shares of Amalco were owned by Vco. 4. ... Following this amalgamation, XXXXXXXXXX % of the shares of Zco remained indirectly owned by Xco. 5. ... The remaining XXXXXXXXXX % of Gco's equity is owned by the XXXXXXXXXX Investors (as to XXXXXXXXXX %) and XXXXXXXXXX Gco will at all relevant times be a controlled foreign affiliate of Zco in which Zco will have a qualifying interest. 13. ...

Favourable rulings issued in XXXXXXXXXX 2004, XXXXXXXXXX 2005, XXXXXXXXXX 2006 and XXXXXXXXXX 2008 with respect to this particular issue. ... DÉSIGNATION DES PARTIES ET ABRÉVIATIONS Dans cette lettre, à l'exception du numéro 20 ci-dessous, le nom et la dénomination sociale du contribuable, de même que certains termes, sont remplacés par les nom, dénomination sociale et abréviations suivants: * XXXXXXXXXX OPCO * XXXXXXXXXX MÈRECO * XXXXXXXXXX (avant sa fusion avec OPCO) GESTION * XXXXXXXXXX (la société issue de la fusion de GESTION et de OPCO) NOUOPCO * " Agence du revenu du Canada " ARC * « Frais d’aménagement au Canada » FAC Au sens du paragraphe 66.2(5) * " Frais d'exploration au Canada " FEC au sens du paragraphe 66.1(6). * Juste valeur marchande JVM * Loi de l'impôt sur le revenu Loi * XXXXXXXXXX XXXXXXXXXX * " Prix de base rajusté " au sens de l'article 54. PBR * " Ressource minérale " au sens du paragraphe 248(1) Ressource Minérale * " Ressource minérale indiquée " Ressource Minérale Indiquée au sens prévu dans le XXXXXXXXXX * " Ressource minérale mesurée " Ressource Minérale Mesurée au sens prévu dans le XXXXXXXXXX * " Société publique " Société Publique au sens du paragraphe 89(1) FAITS 1. ...

XXXXXXXXXX Holdco owns XXXXXXXXXX % of the issued and outstanding shares of XXXXXXXXXX. 27. ... Opinion Provided that, at the Asset Transfer Time, Amalco-MFC is a mutual fund corporation and the Fund is a mutual fund trust for the purposes of the Act, that the fair market value of the Transferred Assets at the Asset Transfer Time is at least 90% of the fair market value of all property owned by Amalco-MFC at the Asset Transfer Time, and provided that the joint election referred to in paragraph (c) of the definition of "qualifying exchange" in subsection 132.2(1) of the July 18, 2005 Draft Amendments is filed in prescribed form within the time set forth in that paragraph, the Asset Transfer, as described in paragraph 43 hereof, will constitute a "qualifying exchange" within the meaning of subsection 132.2(1) of the July 18, 2005 Draft Amendments, such that the rules in subsection 132.2(3) of the July 18, 2005 Draft Amendments will apply to such transfer and to the transactions described in paragraphs 45 and 48 hereof. ... Yours truly, XXXXXXXXXX Section Manager For Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Opinion Provided that, at the Asset Transfer Time, Amalco-MFC is a mutual fund corporation and the Fund is a mutual fund trust for the purposes of the Act, that the fair market value of the Transferred Assets at the Asset Transfer Time is at least 90% of the fair market value of all property owned by Amalco-MFC at the Asset Transfer Time, and provided that the joint election referred to in paragraph (c) of the definition of "qualifying exchange" in subsection 132.2(1) of the July 18, 2005 Draft Amendments is filed in prescribed form within the time set forth in that paragraph, the Asset Transfer, as described in paragraph 27 hereof, will constitute a "qualifying exchange" within the meaning of subsection 132.2(1) of the July 18, 2005 Draft Amendments, such that the rules in subsections 132.2(3) and (4) of the July 18, 2005 Draft Amendments will apply to such transfer and to the transactions described in paragraphs 29 and 32 hereof. As a result of the application of subsections 132.2(3) and (4) of the July 18, 2005 Draft Amendments to the Asset Transfer and to the transactions described in paragraphs 29 and 32 hereof: (a) Amalco-MFC's proceeds of disposition of each particular property that is included in the Transferred Assets and the Fund's cost in respect of each such property will be determined under paragraph 132.2(4)(b) of the July 18, 2005 Draft Amendments to be the lesser of (i) the fair market value of the particular property at the Asset Transfer Time and (ii) the greatest of the cost amount to Amalco-MFC of the particular property at the Asset Transfer Time and the fair market value at the Asset Transfer Time of the consideration (other than Units of the Fund) received by Amalco-MFC for the particular property; (b) except as provided in paragraph 132.2(3)(m) of the July 18, 2005 Draft Amendments, Amalco-MFC's aggregate cost of the Fund Units received by it from the Fund as consideration for the Transferred Assets will be deemed under paragraph 132.2(3)(e) of the July 18, 2005 Draft Amendments to be nil; (c) Amalco-MFC's aggregate proceeds of disposition of the Fund Units distributed to the Fund pursuant to the redemptions described in paragraph 29 hereof will be deemed under paragraph 132.2(3)(f) of the July 18, 2005 Draft Amendments to be equal to the cost amount of the Fund Units to Amalco-MFC immediately before the distribution of the Fund Units to the Fund; (d) the proceeds of disposition to each Unitholder of the Amalco-MFC Class A Shares redeemed by Amalco-MFC in accordance with paragraph 29 hereof will be deemed under subparagraph 132.2(3)(g)(i) of the July 18, 2005 Draft Amendments to be equal to the cost amount to each Unitholder of the Amalco-MFC Class A Shares held by each respective Unitholder immediately before such redemption; (e) with respect to any Amalco-MFC Class A Share disposed of by a Unitholder in accordance with paragraph 29 hereof, pursuant to subsection 131(4) of the Act and subparagraph 132.2(3)(l)(i) of the July 18, 2005 Draft Amendments section 84 of the Act will not apply to deem a dividend to be paid by Amalco-MFC to such Unitholder, nor to deem such Unitholder to have received a dividend on the Amalco-MFC Class A Shares held by such Unitholder; (f) the proceeds of disposition to the Fund of the Amalco-MFC Class B Shares redeemed by Amalco-MFC in accordance with paragraph 29 hereof will be deemed under subparagraph 132.2(3)(g)(i) of the July 18, 2005 Draft Amendments to be equal to the cost amount to the Fund of the Amalco-MFC Class B Shares held by it immediately before such redemption; and (g) with respect to any Amalco-MFC Class B Share disposed of by the Fund in accordance with paragraph 29 hereof, pursuant to subsection 131(4) of the Act and subparagraph 132.2(3)(l)(i) of the July 18, 2005 Draft Amendments section 84 of the Act will not apply to deem a dividend to be paid by Amalco-MFC to the Fund, nor to deem the Fund to have received a dividend on the Amalco-MFC Class B Shares held by it. Yours truly, XXXXXXXXXX Section Manager For Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...