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It is a resident of XXXXXXXXXX for purposes of the Act, the Income Tax Regulations and the XXXXXXXXXX Income Tax Convention. ...

.), c. 1, as amended to the date hereof, and unless otherwise stated, every reference herein to a part, section, subsection, paragraph, subparagraph or clause is a reference to the relevant provision of the Act; (e) "active business" has the meaning assigned by subsection 95(1) of the Act; (f) "Advances" means the moneys advanced by the French Investors to the G.I.E. pursuant to a loan agreement; (g) XXXXXXXXXX; (h) "Canada-France Treaty" means the Canada-France Income and Capital Tax Convention, 1975, as amended to the date hereof; (i) "CBCA" means the Canada Business Corporations Act, R.S.C. 1985, c. ...

Une convention entre actionnaires, signée après le 26 avril 1995, prévoit le rachat par la société des actions de l'enfant décédé, à même le compte de dividendes en capital créé par la réception du produit de la police prise sur la vie de cet enfant. ...

.; (s) "Manager Funded Offerings" means the most recent XXXXXXXXXX offerings of Existing Funds in which the Manager paid the Dealers' commissions; (t) "New Funds" means investment funds to be managed by the Manager and formed as part of (or after) the proposed transactions from time to time; (u) "Program Agent" means XXXXXXXXXX; (v) "Program Documents" include the Arranger's Agreement, the Collection Agency Agreement, the Confirmation Agreement, the Funding Entity Agreement and the Servicing Agreement; (w) "Servicing Agreement" means the agreement among the Manager, the Program Agent and the Funding Entity, as described in paragraph 24; (x) "Treaty" means the 1980 Convention between the United States of America and Canada with Respect to Taxes on Income and Capital and amended (and proposed to be amended) by the First, Second, Third, Fourth and Fifth Protocol; and (y) "Units" means units of New Funds that are mutual fund trusts or shares of New Funds that are mutual fund corporations. ...

Any interest that is ultimately paid on the Core Receivable will be subject to Country 3's withholding tax at the rate of XXXXXXXXXX %, subject to reduction by an applicable income tax convention. ...

(a) XXXXXXXXXX; (b) "Administrator" means XXXXXXXXXX; (c) "ASA" means the Administrative Services Agreement between the Trustee and the Administrator dated XXXXXXXXXX, pursuant to which the Administrator acts as the administrator of the Fund; (d) "Can Holdco" means XXXXXXXXXX; (e) XXXXXXXXXX; (f) "capital property" has the meaning assigned by section 54 of the Act; (g) "Converted Unitholder" means a Unitholder who beneficially owns a Converted Unit; (h) "Converted Unit" means a Unit issued by the Fund on the conversion of the Convertible Debentures, as described in the Proposed Transactions; (i) "Convertible Debentures" means the debentures described in paragraph 15 below; (j) "Exchange" means the XXXXXXXXXX; (k) "Form NR301" means Form NR301, "Declaration of Eligibility for Benefits under a Tax Treaty for a Non-Resident Taxpayer"; (l) "Form NR302" means Form NR302, "Declaration of Eligibility for Benefits under a Tax Treaty for a Partnership with Non-Resident Partners"; (m) "Form NR303" means Form NR303, "Declaration of Eligibility for Benefits under a Tax Treaty for a Hybrid Entity"; (n) "Fund" means XXXXXXXXXX; (o) "mutual fund trust" has the meaning assigned by subsection 132(6) of the Act; (p) "non-portfolio property" has the meaning assigned by subsection 122.1(1) of the Act; (q) "non-resident" has the meaning assigned by subsection 248(1) of the Act; (r) "Offering" means the offer of the Convertible Debentures to the public as described in paragraph 15 below; (s) "person" has the meaning assigned by subsection 248(1) of the Act; (t) "Proposed Transactions" means the transactions which are described in paragraphs 15 to 22 below; (u) "Prospectus" means the short-form prospectus of the Fund dated XXXXXXXXXX, which qualifies the Offering of the Convertible Debentures; (v) "public corporation" has the meaning assigned by subsection 89(1) of the Act; (w) "Qualifying Person" means a person who is a non-resident and who is, within the meaning of the Treaty, both a "resident" of the United States and a "qualifying person" entitled to all of the benefits of the Treaty; (x) "SIFT trust" has the meaning assigned by subsection 122.1(1) of the Act; (y) "taxable Canadian corporation" has the meaning assigned by subsection 89(1) of the Act; (z) "taxable Canadian property" has the meaning assigned by subsection 248(1) of the Act; (aa) "taxation year" has the meaning assigned by subsection 249(1) of the Act; (bb) XXXXXXXXXX; (cc) "Treaty" means the Canada-United States Tax Convention (1980), as amended by all applicable protocols; (dd) "Trust Indenture" means the trust indenture dated XXXXXXXXXX, as amended and restated on XXXXXXXXXX, which governs the Fund; (ee) "Trustee" means XXXXXXXXXX, the trustee of the Fund; (ff) "Unit" means a unit of the Fund representing an equal undivided interest in the Fund; (gg) "unit trust" has the meaning assigned by subsection 108(2) of the Act; (hh) "Unitholder" means a person who beneficially owns a Unit; (ii) "US Opco" means XXXXXXXXXX; and (jj) "US Opco Notes" means the notes described in paragraph 8 below. ...

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. ...

Treaty" means Convention Between Canada and the United States of America 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. ...

"US Limited Partners" means persons resident in the United States of America and entities that are owned by such persons and treated as fiscally transparent under the Code and paragraph 6 of Article IV of the Canada-United States Income Tax Convention. ...

“Treaty” means the XXXXXXXXXX income tax convention. Facts 1. Parent, through its subsidiary corporations, is a XXXXXXXXXX. 2. ...