Canadian Tax Ruling definition

Canadian Tax Ruling means an advance income tax ruling from the Canada Revenue Agency addressing the tax Canadian tax consequences of certain aspects of the Transactions.

Canadian Tax Ruling means the advance income tax ruling issued by the CRA (whether granted prior to, on or after the date hereof) relating to the Butterfly Transactions and includes all supplemental rulings, requests for rulings, information and legal submissions and exhibits to the foregoing.

Canadian Tax Ruling means the advance income tax ruling and opinions received from the CRA with respect to certain aspects of the Pre-Arrangement Reorganization, the Arrangement and certain other transactions and includes any replacements thereof and amendments and supplements thereto received or anticipated to be received from the CRA;

Examples of Canadian Tax Ruling in a sentence

• EnCana has received the Canadian Tax Ruling which confirms that, based on the current provisions of the Tax Act, the transactions as disclosed in this Information Circular will be treated for the purposes of the Tax Act as a tax-deferred “butterfly” reorganization, thereby not imposing any material current Canadian federal income tax on any of EnCana or Cenovus, in general and subject to the comments under “Pre-Arrangement Reorganization”.

• If (i) the Tax consequences to the transactions described in the Canadian Tax Ruling differ from those set out in the Canadian Tax Ruling or if the Tax consequences to the Separation differ from those set out in the recitals of this Agreement and (ii) Sections 3.01, 3.02, 3.03 and 3.04 do not apply, then no indemnity shall be provided for under this Agreement except in the circumstances and to the extent provided for in Sections 4 to 6 and 10.

• If the Tax consequences to the transactions described in the Canadian Tax Ruling differ from those set out in the Canadian Tax Ruling or if the Tax consequences to the transactions forming part of the Separation differ from those set out in the Tax Framework and Sections 3.01, 3.02, 3.03 and 3.04 do not apply, then no indemnity shall be provided for under this agreement except in the circumstances and to the extent provided for in Sections 4 to 7 and 11.

• Assuming the Canadian Tax Ruling is received and the Board determines that any amendment should be made to the Arrangement or the related transactions or if a law, regulation or policy is proposed, enacted, promulgated or applied that may interfere with or is inconsistent with the Canadian Tax Ruling, Toromont may require amendments to the Canadian Tax Ruling in order for it to be in satisfactory form and substance immediately prior to the Arrangement Date.

• The Arrangement Agreement provides that Toromont may, in its sole discretion, obtain an amendment to the Canadian Tax Ruling so long as such amendment is not materially adverse to the other parties to the agreement.

More Definitions of Canadian Tax Ruling

Canadian Tax Ruling means the advance income tax rulings [redacted] received from the CRA with respect to certain Canadian federal income tax consequences in respect of the Pre-Arrangement Transactions, the Arrangement and certain other transactions and any replacements thereof or amendments or supplements thereto received or anticipated to be received from the CRA, in form and substance satisfactory to FirstService, in its sole discretion; [Redaction of the date of the Canadian Tax Ruling] "Certificate of Arrangement" means the certificate of arrangement to be issued by the Director, pursuant to subsection 183(2) of the OBCA, in order to give effect to the Articles of Arrangement;

Canadian Tax Ruling means the advance income tax ruling received by Alcan from the CRA on December 15, 2004 and as may be further revised, supplemented or modified at the request of Alcan confirming the Canadian federal income tax consequences of certain aspects of the Arrangement and certain other transactions.

Canadian Tax Ruling means the advance income tax ruling issued by the Canada Revenue Agency, in respect of Xxxxxxx Canada Inc., dated July 18, 2023.

Canadian Tax Ruling shall have the meaning set forth in the Separation Agreement.

Canadian Tax Ruling means the advance income tax rulings and opinions to be obtained by Toromont from the CRA, as may be further revised, supplemented or modified at the request of Toromont, confirming the Canadian federal income tax consequences of the spinoff by Toromont of the EL Shares under the Arrangement and certain other transactions.

Canadian Tax Ruling means the advance income tax ruling and opinions to be obtained from the CRA and any amendments thereto confirming the Canadian federal income tax consequences of certain aspects of the Arrangement,

Canadian Tax Ruling means the advance income tax rulings and opinions received from the Canada Revenue Agency with respect to certain aspects of the Pre-Arrangement Reorganization, the Arrangement and certain other transactions, and includes any replacements thereof and amendments and supplements thereto received or anticipated to be received from the Canada Revenue Agency;