Search - convention

Le paragraphe 25(1) de la LSA prévoit que "sous réserve des statuts, des règlements administratifs et de toute convention unanime des actionnaires et de l'article 28, les administrateurs peuvent déterminer la date des émissions d'actions, les personnes qui peuvent souscrire et l'apport qu'elles doivent fournir". ...

" Dans la cause Canada Forgings Limited, la question était de savoir si le montant payé aux employés pour l'annulation d'une convention d'option d'achat d'actions dans le cadre d'une prise de contrôle constituait une dépense déductible. ...

Unless otherwise stated, statutory references in this letter are to the Act; (b) "ACB" means adjusted cost base as defined in section 54 of the Act; (c) "ARTOH" means allowable refundable tax on hand as defined in subsection 133(9) of the Act; (d) "business" has the meaning stated in subsection 248(1) of the Act; (e) "Canadian corporation" has the meaning stated in subsection 248(1) 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 on XXXXXXXXXX, and subsequently assigned to NRO One on XXXXXXXXXX, and maturing 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, and maturing on XXXXXXXXXX; (h) "carrying on business" has its extended meaning as stated in subsection 253(1) of the Act; (i) "Corporation" has the meaning stated in subsection 248(1); (j) "FMV" means fair market value; (k) "NRO" means a corporation that has elected to be treated as a non-resident owned investment corporation as defined in subsection 133(8) of the Act; (l) XXXXXXXXXX; (m) "PUC" means paid up capital as defined in subsection 248(1) of the Act; (n) "Taxable Canadian corporation" has the meaning stated in subsection 248(1) of the Act; and (o) "US Treaty" means the Canada-United States Income Tax Convention. ...

La convention de dissolution concernant la Société de Personnes stipulerait que le Dépositaire devrait détenir les placements pour et au nom de ACO, BCO et CCO en respectant et en tenant compte de la quote-part indivise que posséderait chacune de ces sociétés dans les biens leur ayant été attribués par la Société de Personnes lors de sa dissolution. ...

With respect to this transfer, Child D obtained a certificate under section 116 of the Act indicating that the sale to US CO was exempt from tax in Canada pursuant to the Canada-United States Tax Convention, (1980). ...

On XXXXXXXXXX, Holdco entered into a "Convention d'achat d'actions" with XXXXXXXXXX ("Purchaseco") pursuant to which Purchaseco acquired all the assets, properties and rights of Holdco which were, at the time of the offer, used exclusively in connection with the XXXXXXXXXX as well as the shares of XXXXXXXXXX ("R Co") and the shares of XXXXXXXXXX ("M Co"). ...

The employment agreement will provide, among other things: (a) The employee shall perform such duties as Newco may direct from time to time in respect of the Practice; (b) The term of employment shall be from year to year, and may be terminated by either party by XXXXXXXXXX days notice; (c) The amount of annual salary will be negotiated from year to year in respect of each employee and will be paid monthly, subject to the usual source deductions; (d) Newco shall pay all expenses related to the employee's services, including professional membership fees and insurance costs; (e) Newco shall supply all supplies, instruments and equipment as required in the performance of the employee's duties; (f) The employee shall be entitled to compassionate leave and up to XXXXXXXXXX months disability leave with pay; (g) The employee shall be entitled to XXXXXXXXXX days leave with pay to attend conventions and continuing professional education as approved by Newco; (h) The employee shall be entitled to XXXXXXXXXX weeks maternity leave with pay equal to XXXXXXXXXX of the usual remuneration; (i) The employee shall be entitled to XXXXXXXXXX working days vacation each calendar year; and (j) The employee shall agree not to compete with Newco during the term of the employment and for a period of XXXXXXXXXX thereafter. 17. ...

En vertu du paragraphe 149(1.2) de la LIR, le revenu d'une société provenant d'activités exercées en dehors des limites géographiques d'une municipalité ou des municipalités à qui la société appartient ne comprend pas, aux fins de la détermination du pourcentage du revenu provenant de telles activités, le revenu provenant d'activités exercées, aux termes d'une convention écrite avec le Canada, une province ou une municipalité, dans les limites géographiques du Canada, de la province ou de la municipalité respectivement. ...

The employment agreement will provide, among other things: (a) The employee shall perform such duties as Newco may direct from time to time in respect of the Practice; (b) The term of employment shall be from year to year, and may be terminated by either party by XXXXXXXXXX days notice; (c) The amount of annual salary will be negotiated from year to year in respect of each employee and will be paid monthly, subject to the usual source deductions; (d) Newco shall pay all expenses related to the employee's service, including professional membership fees and XXXXXXXXXX insurance costs; (e) Newco shall supply all supplies, instruments and equipment as required in the performance of the employee's duties; (f) The employee shall be entitled to compassionate leave and up to XXXXXXXXXX months disability leave with pay; (g) The employee shall be entitled to up to XXXXXXXXXX days leave with pay to attend conventions and continuing professional education as approved by Newco; (h) The employee shall be entitled to up to XXXXXXXXXX working days vacation each calendar year; and (i) The employee shall agree, for a period of XXXXXXXXXX years after termination of the employment contract, not to provide XXXXXXXXXX services to any of the XXXXXXXXXX without the prior written consent of Newco. 17. ...

The employment agreement will provide, among other things that: (a) The employee shall perform such duties as Newco may direct from time to time in respect of the Practice; (b) The term of employment shall be from year to year, and may be terminated by either party by XXXXXXXXXX days notice; (c) The amount of annual salary will be negotiated from year to year in respect of each employee and will be paid monthly, subject to the usual source deductions; (d) Newco shall pay all expenses related to the employee's service, including professional membership fees and XXXXXXXXXX insurance costs; (e) Newco shall supply all supplies, instruments and equipment as required in the performance of the employee's duties; (f) The employee shall be entitled to compassionate leave and up to XXXXXXXXXX months disability leave with pay; (g) The employee shall be entitled to XXXXXXXXXX days leave with pay to attend conventions and continuing professional education as approved by Newco; and (h) The employee shall be entitled to XXXXXXXXXX calendar weeks vacation each calendar year. 20. ...