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The Paid-up Capital of the Classes of Shares is made up of the sum of the amounts of cash and of the fair market value of the property contributed in favour of ACo in consideration for the issuance of the shares of any of the Classes of Shares, which amounts were added to the Capital, reduced by the amount of any reduction of Capital effected by ACo in favour of the Shareholders XXXXXXXXXX None of the Paid-up Capital of the Classes of Shares is derived from the capitalization of Pre-1972 CSOH in respect of which an election has been made in accordance with the provisions of subsection 83(1) as it read with respect to dividends which became payable before 1979. 4. ...

29 May 2007 Internal T.I. 2007-0223381I7 F- Capital Dividend Account Unedited CRA Tags 83(2) 89(1) 87(2)(z.1); 88(2)(e.2) Principal Issues: In a given fact situation, where a wholly-owned subsidiary is wound-up in its parent corporation and both parent and subsidiary have a CDA immediately before the winding-up, whether the parent must take into consideration the different amounts of its subsiduary's CDA in computing its CDA immediately after the wind-up. ...

The purpose of the Proposed Transactions is to enable Holdings to acquire indirectly approximately XXXXXXXXXX% (but not less than XXXXXXXXXX%) of the units of LP and, in doing so, acquire indirectly XXXXXXXXXX% (but not less than XXXXXXXXXX%) of the businesses operated by OP in as efficient a manner as possible, taking into account securities and other business-regulatory requirements and income-tax considerations in multiple jurisdictions including Canada. ...

The mortgages will be sold, on a fully-serviced basis, by the Issuer for a single aggregate consideration, with respective undivided beneficial ownership interests in such pool represented by XXXXXXXXXX. 8. ...

La Loi sur les sociétés par laquelle est régie la société, le registre des actionnaires, les statuts et règlements de la société de même que la convention unanime des actionnaires sont des éléments qu'il importe de prendre en considération pour déterminer le contrôle de droit d'une société. ...

The Partnership and Bsub 2 will each subscribe, in the same number and amount, for additional Topco Class B shares for cash consideration. 11. ...

En terminant, veuillez prendre en considération que le paragraphe 246(1) est une disposition d'application subsidiaire puisqu'il doit être démontré que la valeur de l'avantage n'est pas par ailleurs incluse (par exemple, en vertu du paragraphe 6(1)a)) dans le calcul du revenu du contribuable en vertu de la partie I de la LIR. ...

In the case under consideration in this ruling, no arrangement for funeral services was to be made at the time of the purchase of the policy, the policy was not established and maintained by a qualifying person, nor was the policy acquired with the contribution to be held in trust or by a qualifying person as required by subsection 148.1(1). ...

The purchase price will be approximately $XXXXXXXXXX, with the consideration of cash in the amount of approximately $XXXXXXXXXX and units of Limited Partnership having a fair market value of approximately $XXXXXXXXXX. 13. ...

This agreement between the parties includes commitments from the Company regarding training and education, employment and business opportunities, environmental management, social and cultural issues and financial compensation in consideration of First Nation support for the Project; (k) "Indian Act" means the Indian Act, R.S.C. 1985, c. ...