Residence of Vendor. The Vendor is not a “non-resident” of Canada within the meaning of the ITA.
Residence of Vendor. The Vendor is a non-resident of Canada within the meaning of Section 116 of the Income Tax Act (Canada).
Residence of Vendor. The Vendor is not a “non-resident” of the United States within the meaning of the Internal Revenue Code and the Regulations.
Residence of Vendor. Other than Willerby, none of the Vendors is a “non-resident” of Canada within the meaning of the Tax Act.
Residence of Vendor. Except for Sirius XM, such Vendor is not a non-resident of Canada within the meaning of the Tax Act.
Residence of Vendor. Other than a Vendor which is a Non-Resident Shareholder set out in Schedule 2.9, the Vendor is not a non-resident of Canada for purposes of section 116 of the ITA.
Residence of Vendor. None of the Holdco Shareholders Group is a non-resident of Canada for purposes of section 116 of the ITA.
Residence of Vendor. Vendor is a resident of the United States for purposes of the Canada-United States Tax Convention (1980), as amended.
Residence of Vendor. The Vendor represents and warrants that he is not a non-resident of Canada within the meaning of the Income Tax Act (Canada) and that he is, in fact, and on closing shall continue to be a resident of Canada within the meaning of that statute.
