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Ruling

2021 Ruling 2020-0871841R3 - Loss consolidation arrangement

At the time of the Proposed Transactions, Lossco will have the borrowing capacity to obtain a commercial loan, in an amount equal to the amount of Loan 1, directly from an arm's length financial institution and this borrowing will not cause Lossco to contravene its debt covenants. ...
Ruling

2023 Ruling 2022-0931631R3 - Loss consolidation arrangement

The principal amount of the Daylight Loan will not exceed the amount that Profitco could reasonably be expected to borrow from an arm’s length financial institution and/or debt capital markets and will not cause Profitco to contravene any debt covenants. 33. ...
Ruling

2023 Ruling 2021-0919771R3 - Loss consolidation arrangement

At the time of the Proposed Transactions, Lossco will have the borrowing capacity to obtain a commercial loan, in an amount equal to the amount of Loan 1, directly from an arm's length financial institution and this borrowing will not cause Lossco to contravene its debt covenants. ...
Ruling

2023 Ruling 2023-0961611R3 - Loss consolidation arrangement

At the time of the Proposed Transactions, Lossco will have the borrowing capacity to obtain a commercial loan, in an amount equal to the amount of Loan 1, directly from an arm's length financial institution and this borrowing will not cause Lossco to contravene its debt covenants. ...
Ruling

2012 Ruling 2011-0425461R3 - Loss consolidation

The principal amount of Loan 2 will not exceed the amount that Lossco could reasonably be expected to borrow from an arm's-length financial institution and will not cause Lossco to contravene its debt covenants. ...
Ruling

1998 Ruling 9826153 - LIMITED PARTNERSHIP ACB ADJUSTMENT

In the event of any failure of a limited partner to comply with such notice, or in the event that the general partner otherwise determines that a person has become a holder or beneficial owner of units in contravention of the residency restrictions, the general partner by written notice to the holder of such units (an "Affected Holder") will require the Affected Holder to sell such units to a person who does not contravene the residency provisions. ...
Ruling

2023 Ruling 2022-0954211R3 - Estate Freeze and Corporate Attribution

Provided that the terms and conditions of the Second Trust are as described in Paragraph 28 and the Second Trust Trustees do not contravene them, subsections 74.1(2) and 74.3(1) will not apply in respect of the settlement of the Second Trust as described in Paragraph 28. ...
Ruling

2005 Ruling 2004-0106481R3 - Employee benefit plan-Shares

Notwithstanding the foregoing, if any provision of the Plan contravenes any applicable laws or regulations or any rules, regulations, by-laws or policies of any regulatory authority or stock exchange having jurisdiction or authority over the Parent, a Participating Company, or the Plan (including the Trust), then the Committee may amend such provision, retroactively or prospectively, to the extent required to bring such provision into compliance therewith. ...

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