Search - convention

.; "G Co" means XXXXXXXXXX; "H Co" means XXXXXXXXXX; "I Co" means XXXXXXXXXX; "J Co" means XXXXXXXXXX; "K Co" means XXXXXXXXXX; "cost amount" has the meaning assigned by subsection 248(1); "CRA" means the Canada Revenue Agency; "DGCL" means the Delaware General Corporation Law, being Chapter 1 of Title 8 of the Delaware Code; "DLLCA" means the Delaware Limited Liability Company Act, being Chapter 18 of Title 6 of the Delaware Code; "FMV" means fair market value and is the highest price available in an open and unrestricted market between informed and prudent parties dealing at arm's length; "IRC" means the Internal Revenue Code of the United States of America; "LLC" means a limited liability company; XXXXXXXXXX "Old C Co" means XXXXXXXXXX; "Proposed Transactions" means those transactions and events described as such below; "subsidiary wholly-owned corporation" has the meaning assigned by subsection 248(1); "Taxable Canadian Corporation" has the meaning assigned by subsection 89(1); "TCP" means taxable Canadian property and has the meaning assigned by subsection 248(1); "Treaty" means the Canada-United States Tax Convention (1980) as amended by the Protocols signed June 14, 1983, March 28, 1984, March 17, 1995 and July 29, 1997; "ULC" means Unlimited Liability Corporation; "U.S. ...

"Customers" refer to Customer A and Customer B; "Home Users" means individuals who purchase or rent the right to view Digital Content through an online store for strictly limited non-commercial personal use; "Customer B" means XXXXXXXXXX; XXXXXXXXXX "Treaty" means the Convention between Canada and the United States of America with respect to taxes on Income and on Capital, September 26, 1980, as amended by the protocols signed on June 14, 1983, March 28, 1984, March 17, 1995, July 29, 1997 and September 21, 2007. ...

DEFINITIONS In this letter, the following terms have the meanings specified below":Canada Group" means Opco1, Opco2 and Salesco; "CBCA" means the Canada Business Corporations Act;"CRA" means the Canada Revenue Agency;"Country X" means XXXXXXXXXX;"XXXXXXXXXXBCA" means the Business Corporations Act (XXXXXXXXXX);"Opco1" means XXXXXXXXXX;"Opco1 Class A Common shares" means the XXXXXXXXXX issued and outstanding Class A Common shares of the capital stock of Opco1;"Opco1 Class J Common shares" means the XXXXXXXXXX issued and outstanding Class J Common shares of the capital stock of Opco1;"Opco2" means XXXXXXXXXX;"Opco2 Class A Common shares" means the XXXXXXXXXX issued and outstanding Class A Common shares of the capital stock of Opco2;"Opco2 Class J Common shares" means the XXXXXXXXXX issued and outstanding Class J Common shares of the capital stock of Opco2;"Opco2 Share Redemption" has the meaning described in paragraph 27;"Parentco" means XXXXXXXXXX;"Parentco Group" has the meaning described in paragraph 13;"Salesco" means XXXXXXXXXX;"Salesco Class A Common shares" means the XXXXXXXXXX issued and outstanding Class A Common shares of the capital stock of Salesco;"Salesco Class J Common shares" means the XXXXXXXXXX issued and outstanding Class J Common shares of the capital stock of Salesco;"Salesco Share Redemption" has the meaning described in paragraph 26;"taxable Canadian corporation" has the meaning assigned by subsection 89(1) of the Act;"Treaty" means the Convention between Canada and the United States of America with Respect to Taxes on Income and on Capital Signed on September 26, 1980, as Amended by the protocols signed on June 14, 1983, March 28, 1984, March 17, 1995, July 29, 1997 and September 21, 2007; "US" means the United States of America;"US Group" means USSalesco1 and the corporations that are related to USSalesco1 within the meaning at subsection 251(2) of the Act, and that carry on an active trade or business in the US, namely, USSalesco2, USOpco1 and USOpco2; "USJVCol" means XXXXXXXXXX;"USJVCo2" means XXXXXXXXXX;"USOpco1" means XXXXXXXXXX;"USOpco2" means XXXXXXXXXX;"USSalesco1" means XXXXXXXXXX;"USSalesco2" means XXXXXXXXXX; FACTS General Corporate Structure 1. ...

MRN, 82 DTC 1431, (1982) CTC 2447, la Commission de révision de l'impôt a déclaré que l'existence de conventions de vote fiduciaire, d'intérêts communs et d'autres liens communs entre les actionnaires constituait un important facteur permettant de déterminer quel groupe contrôlait en réalité deux corporations. 6. ...

Definitions “ACo” means XXXXXXXXXX; “Alpha Debts” means the various loans owing from CCo to ACo; “BCo” means XXXXXXXXXX; “Beta Debts” means the various loans owing from CCo to BCo; “Brand 1” means the XXXXXXXXXX brand name; “CAD” means Canadian dollars; “CBCA” means the Canada Business Corporations Act; “CCo” means XXXXXXXXXX; “Charlie Debts” has the meaning assigned by paragraph 17 below; “Company” means XXXXXXXXXX, the general name of the company as well as the brand name; “Company Group” means ACo and all direct and indirect domestic and foreign subsidiaries of ACo; “Consolidated Group” means the affiliated group of corporations in Country 1 that includes DCo, ECo, FCo, GCo, HCo, and ICo; “Continent” means XXXXXXXXXX; “Country 1” means XXXXXXXXXX; “Country 2” means XXXXXXXXXX; “Country 3” means XXXXXXXXXX; “Country 4” means XXXXXXXXXX; “Country 5” means XXXXXXXXXX; “Country 6” means XXXXXXXXXX; “Country 7” means XXXXXXXXXX; “CRA” means the Canada Revenue Agency; “DCo” means XXXXXXXXXX; “ECo” means XXXXXXXXXX; “FCo” means XXXXXXXXXX; “GCo” means XXXXXXXXXX; “HCo” means XXXXXXXXXX; “ICo” means XXXXXXXXXX; “Qualifying Person” has the meaning assigned by paragraph 2 of Article XXIX-A of the Treaty; “State 1” means XXXXXXXXXX; “State 2” means XXXXXXXXXX; “taxable Canadian corporation” has the meaning assigned by subsection 89(1) of the Act; “Treaty” means the Convention Between the United States of America and Canada with respect to Taxes on Income and on Capital signed on 26 September 1980, as amended by Protocols signed on 14 June 1983, 28 March 1984, 17 March 1995, 29 July 1997 and 21 September 2007; and “USD” means U.S. ...

" means XXXXXXXXXX; "Gross Income" means gross income that is computed pursuant to the Internal Revenue Code of the US; "paid-up capital" has unless otherwise specified, the meaning assigned in the Company Act; "Province 1" means the Province of XXXXXXXXXX; "Province 2" means the Province of XXXXXXXXXX; "qualifying person" has the meaning assigned by paragraph 2 of Article XXIX-A of Treaty 1; "related persons" has the meaning assigned by subsection 251(2); "State 1" means the State of XXXXXXXXXX; "taxable Canadian corporation" has the meaning assigned by subsection 89(1); "taxable dividend" has by virtue of subsection 248(1), the meaning assigned by subsection 89(1); "Treaty 1" means the Convention between Canada and the United States of America with respect to Taxes on Income and Capital signed on September 26, 1980, as amended by protocols signed on June 14, 1983, March 28, 1984, March 17, 1995, July 29, 1997 and September 21, 2007; "Treaty 2" means XXXXXXXXXX; "United States" or "US" means the United States of America; "U.S. ...

The Income Tax Rulings Directorate's ("ITRD") role is to interpret Canada's income tax legislation, (including the Income Tax Act, the Income Tax Regulations, all related statutes and the Income Tax Conventions which Canada has with other countries), and explain how it applies to given situations. ...

Le paragraphe 6(3) édicte essentiellement qu'une somme qu'une personne a reçue d'une autre personne au titre ou en paiement intégral ou partiel d'une obligation découlant d'une convention intervenue entre le payeur et le bénéficiaire immédiatement avant, pendant ou immédiatement après une période où le bénéficiaire était un employé du payeur, est réputé être, pour l'application de l'article XXXXXXXXXX, une rémunération pour les services que le bénéficiaire a rendus pendant la période d'emploi. ...

Treaty” means the Convention Between the United States of America and Canada with Respect to Taxes on Income and on Capital Signed on 26 September 1980, as Amended by the Protocols Signed on 14 June 1983, 28 March 1984, 17 March 1995, 29 July 1997 and 21 September 2007; (u) “US Subs” has the meaning assigned by Paragraph 13; (v) “USCo 1” means XXXXXXXXXX; (w) “USCo 2” means XXXXXXXXXX; and (x) “USCo 3” means XXXXXXXXXX. ...

Le paragraphe 6(3) édicte essentiellement qu'une somme qu'une personne a reçue d'une autre personne au titre ou en paiement intégral ou partiel d'une obligation découlant d'une convention intervenue entre le payeur et le bénéficiaire immédiatement avant, pendant ou immédiatement après une période où le bénéficiaire était un employé du payeur, est réputé être, pour l'application de l'article XXXXXXXXXX, une rémunération pour les services que le bénéficiaire a rendus pendant la période d'emploi. ...