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Où encore, est-il possible pour Revenu Canada d'appliquer des règles analogues à celles contenues dans l'article VII de la convention fiscale Canada- États-Unis? ...

Income Tax Convention, 1980 (the "Canada-U.S. Treaty"). Parentco is a resident of the U.S. with its head office located at XXXXXXXXXX. ...

GESTCOX, GESTCOY et GESTCOZ n'ont pas conclu de convention entre actionnaires relativement à leurs participations dans OPCO et IMMEUBLECO. ...

GESTCOX, GESTCOY et GESTCOZ n'ont pas conclu de convention entre actionnaires relativement à leurs participations dans OPCO et IMMEUBLECO. ...

.), as amended to the date hereof, and, unless otherwise stated, statutory references in this letter are to the Act; (b) "ACB" means "adjusted cost base" as defined in subsection 248(1) of the Act; (c) "business" has the meaning assigned by subsection 248(1) of the Act; (d) "Canadian corporation" has the meaning assigned by subsection 248(1) of the Act; (e) "Canadian property" has the meaning assigned by subsection 133(8) 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 in XXXXXXXXXX and subsequently assigned to NRO One 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; (h) "CGDA" means "capital gains dividend account" as defined in subsection 133(8) of the Act; (i) "carrying on business" has the meaning assigned by its extended meaning under subsection 253(1) of the Act; (j) "corporation" has the meaning assigned by subsection 248(1); (k) "FMV" means fair market value; (l) "NRO" means a corporation that has elected to be treated as a non-resident owned investment corporation as defined under subsection 133(8) of the Act; (m) XXXXXXXXXX; (n) "PUC" means "paid up capital" as defined in subsection 248(1) of the Act; (o) "Taxable Canadian corporation" has the meaning assigned by subsection 248(1) of the Act; (p) "TCP" means "taxable Canadian property" and has the meaning assigned by subsection 248(1) of the Act; and (q) "US Treaty" means the Canada-United States Income Tax Convention (1980). ...

Aucune convention ou résolution concernant la liquidation de PORTCO ou la distribution de ses biens ne prévoira qu'il y aura annulation par PORTCO des actions ordinaires de son capital-actions lors de la liquidation. ...

Income Tax Convention (the "U.S. Treaty"). More particularly, each of U.S. ...

Income Tax Convention [the "Treaty"]). d) "NV" means XXXXXXXXXX. e) "T" means XXXXXXXXXX. f) "U" means XXXXXXXXXX. g) "V" means XXXXXXXXXX. h) "W" means XXXXXXXXXX. i) "X" means XXXXXXXXXX. j) "USOLDCO" means XXXXXXXXXX. k) "CANOLDCO" means XXXXXXXXXX. ...

It is more efficient from a XXXXXXXXXX tax perspective for Foreign Parent to own the shares of the Forcos in a corporation that has access to the benefits of the tax convention between XXXXXXXXXX Certain other controlled foreign affiliates also ceased to be owned by a Canadian resident as a consequence of this transaction. ...

Internal Revenue Code of 1986, as amended to the date hereof; “CRA” means the Canada Revenue Agency; “equity percentage” has the meaning assigned by subsection 95(4); “excluded property” has the meaning assigned in subsection 95(1); “FA1” means XXXXXXXXXX, a corporation incorporated under the General Corporation Law XXXXXXXXXX; “FA2” means XXXXXXXXXX, a limited liability company formed under the laws XXXXXXXXXX; “FA2 common shares” means common shares in the capital stock of FA2; “FA2 preferred shares” means preferred shares in the capital stock of FA2 providing to the holder the right to vote, to have their shares redeemed at a fixed redemption amount of $XXXXXXXXXX per share and a fixed annual dividend entitlement of XXXXXXXXXX%; “fair market value” means the highest price available in an open and unrestricted market between informed and prudent parties dealing at arm’s length and under no compulsion to act, and contracting for a taxable purchase and sale, expressed in terms of money or money’s worth; “foreign accrual property income” has the meaning assigned in subsection 95(1); “foreign accrual tax” has the meaning assigned in subsection 95(1); “foreign affiliate” has the meaning assigned in subsection 95(1); “GPco” means XXXXXXXXXX, a limited liability company existing under the laws XXXXXXXXXX; “income from property” has the meaning assigned by subsection 95(1); “Intermediate LP” means a limited partnership formed or to be formed under the laws of a state of Country 1; “investment business” has the meaning assigned by subsection 95(1); XXXXXXXXXX; “Paragraph” refers to a numbered paragraph in this letter; “Parentco” means XXXXXXXXXX, a corporation existing under XXXXXXXXXX; “Property FA” means a limited liability company without share capital formed or to be formed under the laws of a state of Country 1; “Property LP” means a limited partnership formed or to be formed under the laws of a state of Country 1 (for greater certainty, a Property LP does not including an Intermediate LP); “Property Owner” refers to both the Property LPs and the Property FAs; “public corporation” has the meaning assigned by subsection 248(1); “REIT” means a “real estate investment trust” as defined in section 856(a) of the Country 1 Tax Law; “related person” has the meaning assigned by subsection 251(2); “share” has the meaning assigned by subsection 248(1) and includes all equity interests (within the meaning assigned by subsection 93.2(1)) in limited liability companies that are deemed to be shares under subsection 93.2(2); “Subparagraph” refers to a numbered subparagraph in this letter; “taxable Canadian corporation” has the meaning assigned by subsection 89(1); “taxable capital gain” has the meaning assigned by paragraph 38(a); “taxation year” has the meaning assigned in subsection 249(1); “Transactions” means the transactions described in the Transactions segment of this letter; “Treaty” means Canada-United States Income Tax Convention (1980), as amended; “underlying foreign tax” has the meaning assigned in subsection 5907(1) of the Regulations; “USLP1” means XXXXXXXXXX, a limited partnership existing under the laws XXXXXXXXXX; “USLP1 Limited Partner Unit” means a partnership interest of a limited partner in USLP1, representing a fractional part of the interests of all such partners in USLP1. ...