Search - connection
Results 1 - 10 of 1109 for connection
Administrative Policy summary
Wheeler, "The Connection of Income to a Reserve" (Paper presented to the Insight Aboriginal Conference, March 31, 1995) (C.T.O. "Indians - Connection of Income to a Reserve"). -- summary under Section 87
Wheeler, "The Connection of Income to a Reserve" (Paper presented to the Insight Aboriginal Conference, March 31, 1995) (C.T.O. "Indians- Connection of Income to a Reserve").-- summary under Section 87 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Indian Act- Section 87 ...
Article Summary
Novek, "Employment Benefits May be Tax-Free If Provided in Connection with Special Worksite or Remote Location", Taxation of Executive Compensation and Retirement, October 1991, p. 505. -- summary under Subsection 6(6)
Novek, "Employment Benefits May be Tax-Free If Provided in Connection with Special Worksite or Remote Location", Taxation of Executive Compensation and Retirement, October 1991, p. 505.-- summary under Subsection 6(6) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(6) ...
Article Summary
David Schlesinger, "De Minimis Financial Institutions", 1995 Commodity Tax Symposium Papers, C. 17: Danny Cisterna, "Hot Topics for Financial Institutions," 1999 Commodity Tax Symposium Papers, C. 7: suggests that "relates to" requires a direct connection. -- summary under Section 1
David Schlesinger, "De Minimis Financial Institutions", 1995 Commodity Tax Symposium Papers, C. 17: Danny Cisterna, "Hot Topics for Financial Institutions," 1999 Commodity Tax Symposium Papers, C. 7: suggests that "relates to" requires a direct connection.-- summary under Section 1 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part IX- Section 1 indicates that an investment by a financial institution in dividend-bearing treasury shares of a non-resident company is a zero-rated supply. ...
Article Summary
Carl Irvine, Todd Miller, "Canadian Branch Profits Tax - Challenging the Denial of Treaty-Benefits for US LLCs", Newsletter - TerraLex Connections, 26 December 2013 -- summary under Article 4
Carl Irvine, Todd Miller, "Canadian Branch Profits Tax- Challenging the Denial of Treaty-Benefits for US LLCs", Newsletter- TerraLex Connections, 26 December 2013-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 CRA view that Art. ...
Public Transaction Summary
Progressive/Waste Management -- summary under Inversions
The shares of Progressive will then be consolidated (so that the Waste Connections shareholders have the same number of shares as before) – and Progressive will be renamed Waste Connections by means of amalgamation with a shell Ontario subsidiary with that name. ... Merger Merger Sub will merge with and into Waste Connections (the ''Merger''), with Waste Connections continuing as the surviving corporation and a subsidiary of Progressive. On the Merger, Waste Connections stockholders will receive newly issued Progressive common shares as consideration under the Merger at an exchange ratio of 2.076843 Progressive common shares for every one common share of Waste Connections common stock, so that Progressive and Waste Connections stockholders will hold approximately 30% and 70%, respectively, of post-Merger Progressive common shares. ...
Public Transaction Summary
Progressive/Waste Management -- summary under Reverse takeovers
Progressive/Waste Management-- summary under Reverse takeovers Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Cross-Border Acquisitions- Inbound- Reverse takeovers reverse takeover of Progressive Waste Solutions by Waste Management under Delaware merger Overview It is proposed that Waste Connections, a NYSE-listed Delaware corporation, will effect a reverse takeover of Progressive, a TSX and NYSE-listed OBCA corporation, through a merger of Waste Connections with a Delaware shell sub of Progressive, with Waste Connections as the survivor and with Waste Connections’ shareholders receiving common shares of Progressive so as to end up holding 70% of Progressive. The shares of Progressive will then be consolidated (so that the Waste Connections shareholders have the same number of shares as before) – and Progressive will be renamed Waste Connections by means of amalgamation with a shell Ontario subsidiary with that name. ... Treasury Department and IRS proposals, that could cause intercompany debt if it were to exceed the currently outstanding debt of Waste Connections to be treated as equity, would reduce the adjusted free cash flow expected in the first year following the Merger by less than 3%. ...
Folio Summary
S1-F3-C4 - Moving Expenses -- summary under
Required connection between move and employment/business/education 4.7 To satisfy the condition described in ¶ 4.3(a) or ¶ 4.4 (a), there must be a connection between the individual’s move and one of the following activities: carrying on a business or being employed at a location in Canada or attending an educational institution. Whether such a connection exists in a given situation can only be determined by examining the circumstances surrounding the move. 4.8 The required connection does not exist when an individual moves solely for personal reasons. 4.9 For an employee or self-employed individual, the connection can exist, for example, in the following situations: an employee moves due to a transfer to another establishment of the employer; or a self-employed individual moves for business reasons, such as needing to be closer to a possible market or resources needed for the business (for example natural resources, raw materials, or specialized equipment). Generally, the connection can exist even if there is a delay between the move and the time the business or employment activity at the new work location is undertaken. 4.10 For a student, the connection may exist and an eligible relocation may occur even if a student moves to attend an educational institution as well as to be employed. ...
Folio Summary
S1-F3-C4 - Moving Expenses -- summary under Eligible Relocation
Required connection between move and employment/business/education 4.7 To satisfy the condition described in ¶ 4.3(a) or ¶ 4.4 (a), there must be a connection between the individual’s move and one of the following activities: carrying on a business or being employed at a location in Canada or attending an educational institution. Whether such a connection exists in a given situation can only be determined by examining the circumstances surrounding the move. 4.8 The required connection does not exist when an individual moves solely for personal reasons. 4.9 For an employee or self-employed individual, the connection can exist, for example, in the following situations: an employee moves due to a transfer to another establishment of the employer; or a self-employed individual moves for business reasons, such as needing to be closer to a possible market or resources needed for the business (for example natural resources, raw materials, or specialized equipment). Generally, the connection can exist even if there is a delay between the move and the time the business or employment activity at the new work location is undertaken. 4.10 For a student, the connection may exist and an eligible relocation may occur even if a student moves to attend an educational institution as well as to be employed. ...
Public Transaction Summary
InnVest REIT -- summary under Fund Debenture Offer
" Part XIII tax "By virtue of the fact that the Series G Debentures are convertible into Units of the REIT, there is a risk that both (i) the amount of the Offer Price that exceeds the principal amount of the Series G Debentures (the "Excess"); and (ii) all interest paid or deemed to be paid to a Non-Resident Holder in connection with the Offer could be considered to be participating debt interest, in which case Canadian withholding tax would apply. ... As a result there is a risk that both (i) the Excess; and (ii) all interest paid or deemed to be paid to a Non-Resident Holder in connection with the Offer could be subject to Canadian withholding tax. ...
Public Transaction Summary
Shred-it TRA -- summary under Loss Utilizations/TRAs
In connection with the Offering. Shred-it will acquire all of the common shares of the General Partner. ... In connection with the Offering, Shred-it also will have contributed its general partner interest in Boost Holdings LP to a wholly-owned subsidiary ("New GP"). ... Our payment obligations under the TRA with respect to interests in the Partnership treated as sold for U.S. federal income tax purposes to us in connection with this Offering are expected to be calculated based on the Offering Price, net of Underwriters' Commission and other Offering related costs. ...