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Results 3931 - 3940 of 4117 for convention
Ruling

2004 Ruling 2003-0050071R3 - loss utilization within a corporate group

.), as amended; all statutory references herein are to provisions of the Act unless otherwise specified; "Bank" means the XXXXXXXXXX; "CRA" means the Canada Revenue Agency; "Holdco 2" means XXXXXXXXXX; XXXXXXXXXX; "non-capital loss" has the meaning assigned by subsection 111(8) of the Act; "Target" means XXXXXXXXXX; "taxable Canadian corporation" has the meaning assigned in subsection 89(1) of the Act; "XXXXXXXXXX Parent" means XXXXXXXXXX; "XXXXXXXXXX Treaty" means the Canada-XXXXXXXXXX Tax Convention, as amended. ...
Ruling

2004 Ruling 2003-0047281R3 - Interest and an amalgamation

Definitions In this letter, unless otherwise expressly stated, the following terms have the meanings specified: XXXXXXXXXX; "Offer" means the offer made by Offeror as described in paragraph 8 below and is further described in the definition of "Support Agreement" below; "Offeror" means XXXXXXXXXX and is described in paragraph 3 below; "OfferorSub" means XXXXXXXXXX, a corporation incorporated on XXXXXXXXXX and further described in paragraph 10 below; "capital property" has the meaning assigned by section 54 of the Act; "cost amount" has the meaning assigned by subsection 248(1) of the Act; "depreciable property" has the meaning assigned by subsection 13(21) of the Act; "Holdco" means XXXXXXXXXX and is described in paragraph 2 below; "Lock-up Agreements" means the agreements dated XXXXXXXXXX by Parent, Offeror and XXXXXXXXXX as described in paragraph 6 below; "paid-up capital" has the meaning assigned by subsection 89(1) of the Act; "Parent" means XXXXXXXXXX and is described in paragraph 1 below; "private corporation" has the meaning assigned by subsection 89(1) of the Act; "public corporation" has the meaning assigned by subsection 89(1) of the Act; "subsidiary wholly-owned corporation" has the meaning assigned by subsection 248(1) of the Act; "Support Agreement" means the agreement entered into on XXXXXXXXXX by Parent, Offeror and Target, which provides, among other things, that Parent will, through Offeror, make an offer to acquire all the of the shares of Target at a price of $XXXXXXXXXX per share; "Target" means XXXXXXXXXX and is described in paragraph 4 below; "Target Foreign Subsidiary" means XXXXXXXXXX and is described in paragraph 5 below; "taxable Canadian corporation" has the meaning assigned by subsection 89(1) of the Act; "XXXXXXXXXX Treaty" means the Canada-XXXXXXXXXX Tax Convention, as amended. ...
Ruling

2004 Ruling 2003-0038011R3 - Interpretation of "Occasionally Employed"

Tax Convention, (1980), ("Canada/U.S. Tax Treaty") or such other tax treaty as may be applicable; or (b) a participant elects to have such assets which are held on his behalf transferred to the U.S. ...
Ruling

2001 Ruling 2000-0054593 - Non-resident-owned Investment Corporation

.), as amended as at the date hereof, and each reference to a Part, section, subsection, paragraph, subparagraph or clause is a reference to the specified provision of the Act; (b) "ACB" means "adjusted cost base" as defined in section 54; (c) "Canco Debt" means the indebtedness owing by Canco to NROco, in the amount of $XXXXXXXXXX, pursuant to an agreement entered into between XXXXXXXXXX and Canco and subsequently assigned to NROco on XXXXXXXXXX, as amended pursuant to an agreement entered into on XXXXXXXXXX; (d) "NRO" means "non-resident-owned investment corporation" as defined in subsection 133(8); (e) XXXXXXXXXX; (f) "PUC" means "paid-up capital" as defined in subsection 89(1); (g) "taxable Canadian corporation" has the meaning assigned in subsection 89(1); and (h) "US Treaty" means the Canada-United States Income Tax Convention. ...
Ruling

2001 Ruling 2001-0101813 - Wind--up NRD-Transfer Debt Obligations

.), as amended; (iii) "ACB" means "adjusted cost base" as defined in section 54 of the Act; (iv) "Canco Debt" means the indebtedness owing by Canco to NROco in the aggregate amount of approximately $XXXXXXXXXX, plus accrued and unpaid interest; (v) "NRO" means "non-resident-owned investment corporation" as defined in subsection 133(8) of the Act; (vi) XXXXXXXXXX; (vii) "PUC" means "paid-up capital" as defined in subsection 89(1) of the Act; (viii) "taxable Canadian corporation" has the meaning assigned in subsection 89(1) of the Act; and (ix) "Treaty" means the Canada-United States Tax Convention, (1980). ...
Ruling

2002 Ruling 2002-0123213 F - PHANTOM STOCK PLAN

Le Régime ne constituera pas une convention de retraite au sens du paragraphe 248(1) de la Loi. ...
Technical Interpretation - Internal

23 October 2002 Internal T.I. 2002-0135797 - FOREIGN EXCHANGE LOSSES

One of the conventions of statutory interpretation is that a section of the Act should not be interpreted in a way that would render another provision meaningless. ...
Technical Interpretation - External

4 November 2002 External T.I. 2002-0158885 F - Alloc. of Safe Inc. & Disc. Div. Shares

Ainsi, la répartition ou l'attribution du revenu protégé en main entre des actions de diverses catégories nécessiterait notamment une analyse de tous les droits, privilèges, conditions et restrictions afférents aux catégories d'actions émises et en circulation, de même qu'une analyse des clauses pertinentes d'une convention unanime entre actionnaires, s'il y a lieu, et de la législation sur les sociétés qui serait applicable. ...
Technical Interpretation - Internal

31 October 2002 Internal T.I. 2002-0142497 - FOREIGN EXCHANGE LOSSES

One of the conventions of statutory interpretation is that a section of the Act should not be interpreted in a way that would render another provision meaningless. ...
Technical Interpretation - Internal

27 November 2002 Internal T.I. 2002-0140507 - FOREIGN EXCHANGE LOSS

One of the conventions of statutory interpretation is that a section of the Act should not be interpreted in a way that would render another provision meaningless. ...

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