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Canco est réputé, selon la plupart des conventions fiscales, exploiter son entreprise par le biais d'établissements stables (" ÉS ") situés dans ces pays hôtes étrangers. 3. ...

Persons Entitled to Make Application for a Family Provision Order"; Explanatory Notes to the Justice and Other Legislation (Miscellaneous Provisions) Bill 1997; and Alun A Preece [Lecturer in Law, University of Queensland], "The Impact of the Law of Inheritance on the Family", A Paper delivered at the 7th Australian Institute of Family Studies Conference Sydney Convention and Exhibition Centre, Darling Harbour Sydney, July 24-26, 2000. ...

Accordingly, the determination of residency for the purposes of a tax treaty remains a question of fact, and each case will be decided on its own facts with an eye to the intention of the parties of the particular convention and the purpose of international tax treaties. ...

Une clause d'ajustement de prix sera incluse à la convention d'échange des Actions Ordinaires, et cette clause prévoira que dans l'éventualité où il est déterminé que la JVM des Actions Ordinaires immédiatement avant leur échange est plus ou moins élevée que le total de la valeur de rachat des actions de catégorie " D ", le total de la valeur de rachat des actions de catégorie " D " sera rajusté rétroactivement et tous les ajustements nécessaires, paiements, remboursements, annulation ou émission d'actions requis afin de donner effet à cet ajustement seront effectifs à la Date de clôture. 11. ...

De plus, la JVM d'actions privilégiées de gel comportant les caractéristiques ci-dessus, ne doit pas être réduite en raison de l'existence d'une convention entre actionnaires. ...

CFA1, CFA2, CFA3 and CFA5 are all corporations incorporated in Germany and resident in that country and not resident in Canada for the purposes of the Canada-Germany Income Tax Convention. 3. ...

Nécessairement, la convention d'entente de partage des revenus, telle que prévue au XXXXXXXXXX, sera modifiée afin qu'une portion des revenus bruts gagnés par Société puisse être imposée directement dans Société et éventuellement distribuée sous forme de dividendes. 25. ...

.; (g) "CRA" means the Canada Revenue Agency; (h) "CBCA" means the Canada Business Corporations Act; (i) "Exchange" means the XXXXXXXXXX; (j) "Foreign Country" means United States of America; (k) "GAAP" means Canadian generally accepted accounting principles; (l) "Province" means XXXXXXXXXX; (m) "ULC Province" means XXXXXXXXXX; (n) "Treaty" means the Canada-United States Tax Convention (1980); (o) "First Loan" means ULC's loan payable to Subco as described in paragraph 7; (p) "Second Loan" means Canco's loan payable to the Partnership as described in paragraph 8; (q) "New Loan" means Parent's loan to Canco as described in paragraph 12; (r) "Final Loan" means Subco's proposed loan to ULC as described in paragraph 16; (s) "New Preferred Shares" means the new class of preferred shares of Canco described in paragraph 11; (t) "Canadian partnership" has the meaning assigned by subsection 102(1) of the Act; (u) "fiscal period" has the meaning assigned by subsection 249.1(1) of the Act; (v) "non-capital loss" has the meaning assigned by subsection 111(8) of the Act; (w) "paid-up capital" has the meaning assigned by subsection 89(1) of the Act; (x) "private corporation" has the meaning assigned by subsection 89(1) of the Act; (y) "taxable Canadian corporation" has the meaning assigned by subsection 89(1) of the Act; (z) "taxable dividend" has the meaning assigned by subsection 89(1) of the Act; and (aa) "taxation year" has the meaning assigned by subsection 249(1) of the Act. ...

ACO may, subject to certain exceptions and limitations, be required to pay such additional amounts ("Additional Amounts") to the beneficial owner of any Note or to the beneficial owner of any Note who is a resident of the United States (for purposes of the Canada-United States Tax Convention (1980)) as may be necessary in order that every net payment of the principal of and interest on such Note and any other amounts payable on the Note, after withholding for or on account of any present or future tax, assessment or governmental charge imposed upon such payment by Canada (or any political subdivision or taxing authority thereof or therein), will not be less than the amount provided for in such Note to be then due and payable. 26. ...

Our understanding of the facts, proposed transactions and the purpose of the proposed transactions is as follows: Definitions (a) "Parent" means XXXXXXXXXX; (b) "Canco" means XXXXXXXXXX; (c) "Subco" means XXXXXXXXXX; (d) "DC" means XXXXXXXXXX; (e) "Newco" means XXXXXXXXXX; (f) "Articles" means the Articles attached to the notarial deed creating DC and filed with the appropriate "commercial register" in the Foreign Country; (g) "CBCA" means the Canada Business Corporations Act; (h) "CRA" means the Canada Revenue Agency; (i) "Exchanges" means the XXXXXXXXXX; (j) "Foreign Country" means XXXXXXXXXX; (k) "Foreign Legislation" means the XXXXXXXXXX; (l) "Treaty" means the Canada-XXXXXXXXXX Income Tax Convention; (m) "adjusted cost base" ("ACB") has, by virtue of subsection 248(1) of the Act, the meaning assigned by section 54 of the Act; (n) "arm's length" has the meaning assigned by subsection 251(1) of the Act; (o) "capital property" has, by virtue of subsection 248(1) of the Act, the meaning assigned by section 54 of the Act; (p) "controlled foreign affiliate" has, by virtue of subsection 248(1) of the Act, the meaning assigned by subsection 95(1) of the Act; (q) "foreign affiliate" has, by virtue of subsection 248(1) of the Act, the meaning assigned by subsection 95(1) of the Act; (r) "non-resident" has the meaning assigned by subsection 248(1) of the Act; (s) "paid-up capital" has, by virtue of subsection 248(1) of the Act, the meaning assigned by subsection 89(1) of the Act; (t) "public corporation" has, by virtue of subsection 248(1) of the Act, the meaning assigned by subsection 89(1) of the Act; (u) "share" has the meaning assigned by subsection 248(1) of the Act; (v) "specified participating interest" will, provided that Bill C-10 (which received First Reading in the Senate on October 30, 2007) is enacted as originally proposed, have the meaning assigned by the proposed amendment to subsection 248(1) of the Act; (w) "subsidiary wholly-owned corporation" has the meaning assigned by subsection 248(1) of the Act; and (x) "taxable Canadian corporation" has, by virtue of subsection 248(1) of the Act, the meaning assigned by subsection 89(1) of the Act. ...