Search - convention

Où encore, est-il possible pour Revenu Canada d'appliquer des règles analogues à celles contenues dans l'article VII de la convention fiscale Canada- États-Unis? ...

Qui plus est, le Contribuable était assuré de toucher de l'Institution financière la valeur plancher déterminée dans la convention de SWAP. ...

Income Tax Convention, 1980 (the "Canada-U.S. Treaty"). Parentco is a resident of the U.S. with its head office located at XXXXXXXXXX. ...

GESTCOX, GESTCOY et GESTCOZ n'ont pas conclu de convention entre actionnaires relativement à leurs participations dans OPCO et IMMEUBLECO. ...

GESTCOX, GESTCOY et GESTCOZ n'ont pas conclu de convention entre actionnaires relativement à leurs participations dans OPCO et IMMEUBLECO. ...

.), as amended to the date hereof, and, unless otherwise stated, statutory references in this letter are to the Act; (b) "ACB" means "adjusted cost base" as defined in subsection 248(1) of the Act; (c) "business" has the meaning assigned by subsection 248(1) of the Act; (d) "Canadian corporation" has the meaning assigned by subsection 248(1) of the Act; (e) "Canadian property" has the meaning assigned by subsection 133(8) of the Act; (f) "Canco Debt A" means the indebtedness owing by Canco to NRO One in the amount of $XXXXXXXXXX pursuant to an agreement entered into between XXXXXXXXXX and Canco in XXXXXXXXXX and subsequently assigned to NRO One on XXXXXXXXXX; (g) "Canco Debt B" means the indebtedness owing by Canco to NRO Two in the amount of $XXXXXXXXXX pursuant to an agreement entered into between XXXXXXXXXX and Canco on XXXXXXXXXX and subsequently assigned to NRO Two on XXXXXXXXXX; (h) "CGDA" means "capital gains dividend account" as defined in subsection 133(8) of the Act; (i) "carrying on business" has the meaning assigned by its extended meaning under subsection 253(1) of the Act; (j) "corporation" has the meaning assigned by subsection 248(1); (k) "FMV" means fair market value; (l) "NRO" means a corporation that has elected to be treated as a non-resident owned investment corporation as defined under subsection 133(8) of the Act; (m) XXXXXXXXXX; (n) "PUC" means "paid up capital" as defined in subsection 248(1) of the Act; (o) "Taxable Canadian corporation" has the meaning assigned by subsection 248(1) of the Act; (p) "TCP" means "taxable Canadian property" and has the meaning assigned by subsection 248(1) of the Act; and (q) "US Treaty" means the Canada-United States Income Tax Convention (1980). ...

Aucune convention ou résolution concernant la liquidation de PORTCO ou la distribution de ses biens ne prévoira qu'il y aura annulation par PORTCO des actions ordinaires de son capital-actions lors de la liquidation. ...

Income Tax Convention (the "U.S. Treaty"). More particularly, each of U.S. ...

Income Tax Convention [the "Treaty"]). d) "NV" means XXXXXXXXXX. e) "T" means XXXXXXXXXX. f) "U" means XXXXXXXXXX. g) "V" means XXXXXXXXXX. h) "W" means XXXXXXXXXX. i) "X" means XXXXXXXXXX. j) "USOLDCO" means XXXXXXXXXX. k) "CANOLDCO" means XXXXXXXXXX. ...

(a) “ACB” has the meaning assigned to the expression “Adjusted Cost Base” in section 54 of the Act; (b) “Act” means the Income Tax Act, R.S.C. 1985 (5th Supp.) c. 1, as amended from time to time and consolidated to the date of this letter and, unless otherwise expressly stated, every reference herein to a part, section or subsection, paragraph or subparagraph and clause or subclause is a reference to the relevant provision of the Act; (c) “CBCA” means the Canada Business Corporations Act; (d) “CRA” means the Canada Revenue Agency; (e) “FMV” means fair market value; (f) “Initial Bid” means the initial unsolicited take-over bid announced on XXXXXXXXXX, by Xco, to acquire all of the shares of the capital stock of Parent, as described in Paragraph 27; (g) “Memorandum of Understanding” means the memorandum of understanding between Parent, Xco and other parties dated XXXXXXXXXX, as described in Paragraphs 28, 30 and 32; (h) “non-resident” has the meaning assigned by subsection 248(1); (i) “Offer” means the offer formally launched on XXXXXXXXXX, by Parent, through Bidco, to acquire all of the Target Shares, as amended on XXXXXXXXXX, as described in Paragraphs 12, 14, 16 and 17; (j) “paid-up capital” has the meaning assigned by subsection 89(1); (k) “Post-Take-over Merger” means the proposed merger of Xco with Parent, as described in Paragraph 30; (l) “private corporation” has the meaning assigned by subsection 89(1); (m) “public corporation” has the meaning assigned by subsection 89(1); (n) XXXXXXXXXX; (o) “Report” means the report filed on XXXXXXXXXX with Canadian securities commissions by the Investment Managers under XXXXXXXXXX; (p) “Revised Bid” means the amended bid made by Xco to acquire all of the shares of the capital stock of Parent, resulting from modifications made to the Initial Bid on XXXXXXXXXX, as described in Paragraph 28; (q) “Specified Shareholder” has the meaning assigned by subparagraph 88(1)(c.2)(iii) and subsection 248(1); (r) “subsidiary wholly-owned corporation” has the meaning assigned by subsection 248(1); (s) “Target Shares” means all of the issued and outstanding common shares of the capital stock of Target; (t) “taxable Canadian corporation” has the meaning assigned in subsection 89(1); (u) “Treaty” means the Convention Between The Government of Canada and XXXXXXXXXX; (v) XXXXXXXXXX. ...