Search - connection

Results 111 - 120 of 15462 for connection

S4-F2-C1 - Deductibility of Fines and Penalties -- summary under Subparagraph 40(1)(a)(i)

S4-F2-C1- Deductibility of Fines and Penalties-- summary under Subparagraph 40(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(1)- Paragraph 40(1)(a)- Subparagraph 40(1)(a)(i) 1.22 If a fine or penalty (such as a mortgage prepayment penalty) is incurred in connection with the disposition of a capital property, the fine or penalty is taken into account under subsection 40(1) for purposes of calculating any gain or loss on that disposition. ...

Loblaw/GWL/Choice -- summary under Butterfly spin-offs

Due Bill Trading Due Bill trading may only be used in connection with a “push-out” of listed securities (i.e. where the certificates representing the originally listed securities to which the entitlement attaches will not be replaced with new certificates; rather, only the entitlement (e.g. the dividend, shares of a new company, etc.) will be “pushed-out” to shareholders). In the case of the Arrangement, this means that Due Bill trading will only be used in connection with the LCL Common Shares, as the certificates representing the LCL Common Shares will not be replaced with new certificates. ...

S2-F1-C2 - Retiring Allowances -- summary under Retiring Allowance

In this context, the words in respect of have been held by the courts to imply a connection between the loss of employment and the subsequent receipt, where the primary purpose of the payment is to compensate for the loss of employment. Two questions set out by the courts to determine whether such a connection exists for purposes of a retiring allowance are as follows: Question 1 – But for the loss of employment would the amount have been received? ...

S4-F8-C1 - Business Investment Losses -- summary under Subsection 39(9)

Therefore, in connection with the disposition of the debt, Mr. R’s 2015 tax return will also reflect an allowable capital loss in the amount of $60,000 ($120,000 x one-half). ...

S4-F14-C1 - Artists and Writers -- summary under Commodities, and commodities futures and derivatives

An artist would generally be considered to have made a gift of capital property when the property gifted is property that would not normally be produced and sold in connection with their business. ...

S1-F2-C3 - Scholarships, Research Grants and Other Education Assistance -- summary under Paragraph 56(1)(r)

S1-F2-C3- Scholarships, Research Grants and Other Education Assistance-- summary under Paragraph 56(1)(r) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(r) The deduction [under s. 110(1)(g) by way of s. 56(1)(r)] applies only to tuition assistance and not to other types of assistance a student may receive in connection with the student's training. ...

S3-F10-C1 - Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs -- summary under Paragraph 146(4)(a)

This position does not apply to borrowing that arises in connection with a cashless exercise of warrants or a margin account. ...

B2Gold -- summary under Convertible Debentures

Make-whole Where a holder elects to convert its Notes in connection with a make-whole fundamental change or a redemption notice, the Company will, under certain circumstances, increase the conversion rate by a number of additional common shares based on a table, so that the specified make-whole is lower for (fundamental change or redemption) triggering dates closer to the maturity date. ...

Metro/PJC -- summary under Triangular Amalgamations

Qualifying Holdco Alternative Metro will permit each registered owner (a "Qualifying Holdco Shareholder") that is resident in Canada, is not exempt under Part I of the Tax Act (including a partnership if all of the members of the partnership are resident in Canada), transfers all of its Shares to the Qualifying Holdco and elects in respect of such Shares to include in the Amalgamation a corporation (a "Qualifying Holdco") that meets conditions including those described below (the "Holdco Alternative"): the Qualifying Holdco was incorporated under the QBCA not earlier than January 15, 2018, unless written consent is obtained from Metro; such Qualifying Holdco will not be comprised of more than three classes of shares, two classes of common shares and one class of preferred shares, the terms and conditions of which will be determined in consultation with Metro; such Qualifying Holdco is a single purpose corporation that has not carried on any business, has no employees, never holds any assets other than Shares and nominal cash, has never entered into any transaction other than under the Holdco Alternative except as consented to by Metro; such Qualifying Holdco has no liabilities; such Qualifying Holdco will not have unpaid declared dividends and will not have paid any dividends or other distributions, other than an increase in stated capital, a stock dividend, a cash dividend financed with a daylight loan or a dividend paid through the issuance of a promissory note with a determined principal amount and any such promissory note issued in relation to the payment of any such dividend will have been capitalized into such Qualifying Holdco and no longer be outstanding as of the Effective Time; without written Metro consent, such Qualifying Holdco will not have made any election or designation under the Tax Act other than eligible dividend designations and any s. 85 election; such Qualifying Holdco will have no shares outstanding other than shares held by such Qualifying Holdco Shareholder or its Qualifying Holdco Shareholder Subsidiary; such Qualifying Holdco will have not more than three directors and three officers; such Qualifying Holdco Shareholder will at its cost and in a timely manner prepare and file all income tax returns of such Qualifying Holdco in respect of the taxation year of such Qualifying Holdco ending immediately prior to the Amalgamation, subject to Metro's right to approve all such returns as to form and substance; such Qualifying Holdco Shareholder will indemnify PJC and Metro, and any successor thereof, for any and all liabilities of such Qualifying Holdco in a form satisfactory to Metro acting reasonably; access to the books and records of such Qualifying Holdco will have been provided; the terms and conditions of such Holdco Alternative must be satisfactory to Metro and PJC; and such Qualifying Holdco Shareholder will be required to pay all reasonable out-of-pocket expenses incurred by Metro or PJC in connection with the Holdco Alternative Canadian tax consequences A Resident Holder whose Shares are converted into Amalco Redeemable Shares and/or Metro Shares on the Amalgamation will not realize any capital gain or capital loss as a result of the conversion. ...

Vistra/Crius -- summary under REIT/LP sales proceeds distribution

As a result, no double taxation should result from any capital gain being allocated by the Trust to Unitholders in connection with the redemption of their Units. ...

You are here