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The income and assets of the respective sub-fund are segregated and each sub-fund is only liable for its own liabilities; “CRA” means the Canada Revenue Agency; “Custodian Bank” means XXXXXXXXXX, acting as custodian with respect to the Fund’s property as set out in the Fund Contract; “Designated Stock Exchange” has the meaning assigned by subsection 248(1); “Foreign Legislation 1” means the Swiss Federal Act on Collective Investment Schemes of June 23, 2006; “Foreign Legislation 2” means the Swiss Ordinance on Collective Investment Schemes of November 22, 2006 in respect of the Foreign Legislation 1; “Fund” means a XXXXXXXXXX; “Fund Assets” means the assets governed by the Fund Contract XXXXXXXXXX, XXXXXXXXXX; “Fund Contract” means the fund contract dated XXXXXXXXXX between the Unitholders, the Management Company and the Custodian Bank, providing for the establishment of the Umbrella Fund and its Sub-funds; “Fund Unit” means a unit of the Fund conferring an entitlement to the Fund Assets and to the income of the Fund proportionate to the fraction it represents of total Fund Units existing at a moment in time; “Management Company” means XXXXXXXXXX, a resident of Switzerland, acting in its capacity as the manager of the Fund as set out in the Fund Contract; “Net Asset Value” means the market value of the Fund Assets at a particular time as determined pursuant to the Fund Contract; “Net Asset Value per Unit” means the market value of the Fund at a particular time as determined pursuant to the Fund Contract divided by the number of issued and outstanding Fund Units; “Non-Resident” has the meaning assigned by subsection 248(1); “Open-ended Collective Investment Scheme” means a Collective Investment Scheme, established under the laws of Switzerland, authorized by the Authority pursuant to Title 2 of the Foreign Legislation 1, in respect of which unitholders are entitled to redeem their units; “Redemption” means the redemption of a Fund Unit that each Unitholder is entitled to request from the Fund Management Company or that is initiated by the Fund Management Company; “Redemption Time” means the time when a Redemption occurs; “related persons” has the meaning assigned by subsection 251(2); “Sub-fund” means XXXXXXXXXX, each a Collective Investment Scheme, in its own right, within the Umbrella Fund; “Tax Treaty” means a tax treaty as defined in subsection 248(1); “TCP” means taxable Canadian property as defined in subsection 248(1); “Treaty” means the Convention between Canada and Switzerland for the Avoidance of Double Taxation with respect to Taxes on Income and Capital; “Umbrella Fund” means XXXXXXXXXX”, which is an Open-Ended Collective Investment Scheme composed of various Sub-funds including the Fund; “Unitholder” means any person holding Fund Units, such holder being entitled to a value equal to its share in the undivided assets of the Fund; “Unitholder Liability for Tax” means the liability for tax, interest and penalty of any Unitholder under the Act that may arise in connection with the holding of Fund Units; “Withholding Tax Exemption” means the exemption that a resident of Switzerland can claim in respect of part XIII withholding tax payable on dividends paid or credited by a resident of Canada pursuant to Article 10(3)(b) of the Treaty; and “Withholding Tax Obligation” means any legal obligation of the Canadian Sub-Custodian to withhold any amount in application of the Act, or the Canadian Agreement. ...

X qui a été souscrite il y a plusieurs années aux fins de la convention entre actionnaires. ...

X qui a été souscrite il y a plusieurs années aux fins de la convention entre actionnaires. ...

En 1977, le contribuable a conclu avec un promoteur immobilier une convention d'achat pour l'édifice à bureaux. ...