Search - convention

Results 4111 - 4111 of 4111 for convention
Ruling

2024 Ruling 2023-0987001R3 - Public Spin-Off Butterfly

., a corporation incorporated under Act 2 and a TCC; “Sub 14” means XXXXXXXXXX, a corporation incorporated under Act 2 and a TCC; “Sub 15” means XXXXXXXXXX, a XXXXXXXXXX company formed in XXXXXXXXXX and a non-resident of Canada for purposes of the Act; “Sub 16” means XXXXXXXXXX, a XXXXXXXXXX company formed under the XXXXXXXXXX and a non-resident of Canada for purposes of the Act; “Sub 17” means XXXXXXXXXX, a XXXXXXXXXX company formed under the XXXXXXXXXX and a non-resident of Canada for purposes of the Act; “Sub 18” means XXXXXXXXXX, a XXXXXXXXXX company formed under the XXXXXXXXXX and a non-resident of Canada for purposes of the Act; “Sub 19” means XXXXXXXXXX, a XXXXXXXXXX company formed under the XXXXXXXXXX and a non-resident of Canada for purposes of the Act; “Sub 20” means XXXXXXXXXX, LLC, a XXXXXXXXXX company formed under the XXXXXXXXXX and a non-resident of Canada for purposes of the Act; “Sub 21” means XXXXXXXXXX, a corporation incorporated under Act 1 and a TCC; “Sub 22” means XXXXXXXXXX formed under the XXXXXXXXXX and a non-resident of Canada for purposes of the Act; “Tax Treaty” means the Convention Between Canada and XXXXXXXXXX, as amended; “taxable Canadian corporation” or “TCC” means “taxable Canadian corporation” as defined in subsection 89(1); “taxable Canadian property” has the meaning assigned by subsection 248(1); “taxation year” has the meaning assigned by subsection 249(1); XXXXXXXXXX means XXXXXXXXXX; “transferee corporation” has the meaning assigned in the definition of “distribution” in subsection 55(1); XXXXXXXXXX; and “XXXXXXXXXX Business” means the Group’s XXXXXXXXXX business in XXXXXXXXXX. ...

Pages