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For the purposes of Part XIII withholding and section 116, any amount paid or credited by a payer to the Sub-Custodians in respect of property held by a Sub-Fund on behalf of the New Investors, including purchase consideration for such property, will be considered an amount paid or credited to the New Investor in proportion to its co-ownership interest in the assets and Gross Income of the particular Sub-Fund. ...

For purposes of the Guidelines, one must take into consideration the location where the duties of employment are performed, when less than 90% of the duties of employment are performed on a reserve the exemption in Guideline 1 can be prorated. ...

Accordingly, although the analysis in Mobil should be given serious consideration in interpreting the word "production", it is critical to note that the wording in section 1204 of the Regulations is quite different than the words in the Excise Tax Act that were the subject of interpretation Mobil. ...

In consideration for the transfers described in paragraph 14 above, HoldcoK, HoldcoL and HoldcoM will each issue that number of preferred shares of its capital stock to Amalco having an aggregate fair market value and redemption amount equal to the aggregate fair market value of the property acquired by HoldcoK, HoldcoL and HoldcoM, respectively. 16. ...

Le même jour, Mère #3 a transféré une partie de ces biens à Filiale pour une considération de XXXXXXXXXX $, soit le prix payé au tiers pour cette partie des biens. 4.7 Le XXXXXXXXXX, Mère #3 a emprunté XXXXXXXXXX $, auprès deXXXXXXXXXX afin de financer partiellement l'acquisition des biens d'entreprise mentionnés au paragraphe 4.6 ci-dessus. 5. ...

Our rulings are based on the Act in its present form and do not take into consideration any proposed amendments to the Act. ...

If the Company issues Common Shares as aforesaid, such Common Shares will be issued in consideration for the past services of the Eligible Director to the Company and the entitlement of the Eligible Director under this Plan shall be satisfied in full by such issuance of the Common Shares. ...

Provided that the Partnership winds up its affairs within 60 days from the date of the transfer of Assets (described in paragraph 3 of the Facts) immediately before the winding-up there was no Partnership property other than money or property received from Newco as consideration for the disposition, the provisions of paragraphs 85(3)(d) to (h) of the Act will apply. ...

Nevertheless we recognize that consideration must be given to accounting terminology. ...

Toutefois, le principe du rattachement demeure un facteur à prendre en considération dans la détermination de l’image la plus fidèle possible du bénéfice. ...