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Le Régime ne constituera pas une convention de retraite au sens du paragraphe 248(1) de la Loi. ...

Former Foreign Affiliate is a corporation incorporated in and resident in Foreign country #4; (hh) "GAAP" means Canadian Generally Accepted Accounting Principles; (ii) "Group Business" means the XXXXXXXXXX business, XXXXXXXXXX; (jj) "paid-up capital" has the meaning assigned by subsection 89(1); (kk) "Paragraph" means a numbered paragraph in this advance income tax ruling; (ll) "Proposed Transactions" means the transactions described in Paragraph 24 to Paragraph 27; (mm) "related person" has the meaning assigned by subsection 251(2); (nn) "series of transaction or events" means "series of transactions or events" for purposes of the Act as modified by subsection 248(10); (oo) "specified non-resident shareholder" has the meaning assigned by subsection 18(5); (pp) "stated capital" has the meaning assigned by the Company Act; (qq) "taxable Canadian corporation" has the meaning assigned by subsection 89(1); (rr) "TC" means Taxation Centre; (ss) "Treaty" means the Canada- XXXXXXXXXX Tax Convention XXXXXXXXXX, as amended to the date hereof; and (tt) "TSO" means Tax Services Office. ...

Aucune convention entre actionnaires n'a été conclue par les actionnaires de GESTCO1. 5. ...

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. ...

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. ...

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. ...

ABRÉVIATIONS ET DÉFINITIONS Dans cette lettre, à l’exception du numéro 32, les noms et dénominations sociales des contribuables sont remplacés par les noms et dénominations sociales suivants. « A » désigne XXXXXXXXXX; « B » désigne XXXXXXXXXX; « EA » désigne XXXXXXXXXX, fils de A; « Fiducie1 » désigne la Fiducie XXXXXXXXXX créée en vertu des dispositions XXXXXXXXXX aux termes d’une convention de fiducie reçue le XXXXXXXXXX; « Fiducie2 » désigne la Fiducie testamentaire EA, créée au terme du Testament; « Fiducie3 » désigne la Fiducie testamentaire PEA1, créée au terme du Testament; « Fiducie4 » désigne la Fiducie testamentaire PEA2, créée au terme du Testament; « Légataires universels résiduaires » désigne collectivement Fiducie2, Fiducie3 et Fiducie4; « Liquidateur » désigne XXXXXXXXXX; « Nouco » désigne la société XXXXXXXXXX constituée le XXXXXXXXXX en vertu de la LCSA; « PEA1 » désigne XXXXXXXXXX, fille d’EA; « PEA2 » désigne XXXXXXXXXX, fils d’EA; « Société » désigne la société XXXXXXXXXX; « Succession » désigne la succession de A; « Testament » désigne le dernier testament de A. ...