advance tax ruling definition

advance tax ruling means a written statement in the form of a binding general ruling, binding private ruling and binding class ruling issued by the Commissioner-General regarding the interpretation or application of the relevant Act;
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advance tax ruling means a written statement in the form of a binding
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advance tax ruling means the advance income tax ruling of the CRA which has been applied for by the Trust in connection with the Arrangement in order to confirm the anticipated tax treatment resulting from the transactions contemplated by the Plan of Arrangement;
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More Definitions of advance tax ruling

advance tax ruling. ’ means the advance income tax ruling of the CRA which has been applied for by the Fund in connection with the Reorganization including, for greater certainty, any opinions of CRA set out in the advance tax ruling.
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advance tax ruling means a written statement issued by the Commissioner regarding the interpretation or application of the Act and is limited to a binding general ruling under section 76P, a binding private ruling under section 76Q, or a binding class ruling under section 76R;
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advance tax ruling means the advanced income tax ruling and opinion to be obtained from the Canada Revenue Agency and any amendments thereto confirming the Canadian federal income tax consequences of certain aspects of the Arrangement.
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advance tax ruling means the advance income tax ruling of the CRA which has been applied for by the Trust in connection with the Arrangement;
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advance tax ruling in respect of a Ratifying KCN means a favourable advance tax ruling from the Canada Revenue Agency related to the structure of its investment in the Limited Partnership, in substantially the form set out in its ruling request made to the Canada Revenue Agency, a copy of which request shall have been provided to Hydro on or before the date of this Ratification Protocol.
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Related to advance tax ruling

  • Tax Ruling as used in this Agreement, shall mean a written ruling of a taxing authority relating to Taxes. "Closing Agreement", as used in this Agreement, shall mean a written and legally binding agreement with a taxing authority relating to Taxes.

  • advance ruling means a decision provided by the Authority or the Appellate Authority to an applicant on matters or on questions specified in sub-section (2) of section 97 or sub-section (1) of section 100, in relation to the supply of goods or services or both being undertaken or proposed to be undertaken by the applicant;

  • council tax benefit means council tax benefit under Part 7 of the SSCBA; “couple” has the meaning given by paragraph 4;

  • IRS Ruling shall have the meaning set forth in the Recitals.

  • Transaction Tax Deductions means any Tax deductions relating to (i) the Company Transaction Expenses, and (ii) repayment of the Indebtedness, including any unamortized deferred financing fees in connection with the Indebtedness.

  • Income Tax Return means any return, declaration, report, claim for refund, or information return or statement relating to Income Taxes, including any schedule or attachment thereto, and including any amendment thereof.

  • Input Tax Credit means the credit of input tax;

  • Issuer Tax Opinion means with respect to any action, an Opinion of Counsel to the effect that, for federal income tax purposes and subject to customary assumptions and qualifications for opinions of this type, (a) such action will not adversely affect the tax characterization as debt of any Notes that were characterized as debt at the time of their issuance, and (b) following such action neither the Issuer nor the Titling Trust will be treated as an association (or publicly traded partnership) taxable as a corporation.

  • Presumed Tax Rate means the highest effective marginal statutory combined U.S. federal, state and local income tax rate prescribed for an individual residing in New York City (taking into account (i) the deductibility of state and local income taxes for U.S. federal income tax purposes, assuming the limitation of Section 68(a)(2) of the Code applies and taking into account any impact of Section 68(f) of the Code, and (ii) the character (long-term or short-term capital gain, dividend income or other ordinary income) of the applicable income).

  • Transaction Payroll Taxes means the employer portion of any payroll or employment Taxes incurred or accrued with respect to any bonuses, option exercises, payments to employee stock option holders or other compensatory payments made in connection with the transactions contemplated by this Agreement.

  • Excise Tax Act means the Excise Tax Act (Canada);

  • alternative maximum council tax reduction means the amount determined in accordance with paragraph 31 and Schedule 4;

  • Pre-Closing Tax Return has the meaning set forth in Section 7.1(a).

  • Straddle Tax Period means a Tax period that begins on or before the Closing Date and ends after the Closing Date.

  • Advance Ruling Certificate means an advance ruling certificate issued by the Commissioner of Competition pursuant to section 102 of the Competition Act with respect to the transactions contemplated by this Agreement.

  • Tax roll means a permanent record of the taxes charged on property, as extended

  • maximum council tax reduction amount means the amount determined in accordance with paragraph 29;

  • Agreement combined tax rate means the sum of the tax rates:

  • Income Tax Act means the Income Tax Act, 1962 (Act No. 58 of 1962);

  • Pre-Tax Income means income, as determined by GAAP, prior to deduction of the Bonus Pool (as hereinafter defined) and income taxes, and if applicable, after the deduction of any bonus pool of a future officer bonus plan adopted by the Company relating to an applicable Award Year and adjustments approved by the Board as described herein.

  • Book-Tax Disparity means with respect to any item of Contributed Property or Adjusted Property, as of the date of any determination, the difference between the Carrying Value of such Contributed Property or Adjusted Property and the adjusted basis thereof for federal income tax purposes as of such date. A Partner’s share of the Partnership’s Book-Tax Disparities in all of its Contributed Property and Adjusted Property will be reflected by the difference between such Partner’s Capital Account balance as maintained pursuant to Section 5.5 and the hypothetical balance of such Partner’s Capital Account computed as if it had been maintained strictly in accordance with federal income tax accounting principles.

  • Production Tax Credit or “PTC” means the tax credit for electricity produced from certain renewable generation resources described in Section 45 of the Internal Revenue Code of 1986, as it may be amended or supplemented from time to time.

  • Assumed Tax Rate means the highest effective marginal combined U.S. federal, state and local income tax rate for a Fiscal Year prescribed for an individual or corporate resident in New York, New York (taking into account (a) the nondeductiblity of expenses subject to the limitation described in Section 67(a) of the Code and (b) the character (e.g., long-term or short-term capital gain or ordinary or exempt income) of the applicable income, but not taking into account the deductibility of state and local income taxes for U.S. federal income tax purposes). For the avoidance of doubt, the Assumed Tax Rate will be the same for all Partners.

  • Income Tax Returns means all Tax Returns relating to Income Taxes.

  • Post-Closing Tax Period means any taxable period beginning after the Closing Date and the portion of any Straddle Period beginning after the Closing Date.

  • Post-Distribution Tax Period means a Tax year beginning and ending after the Distribution Date.