Examples of Canadian ITA in a sentence
The Canadian Sub-Agent is not a non-resident of Canada for purposes of Part XIII of the Canadian ITA and, as such, it and not the Administrative Agent has been designated under this Agreement to carry out certain duties of the Administrative Agent in respect of TCCI.
The Canadian Sub-Agent is not a non-resident of Canada for purposes of Part XIII of the Canadian ITA and, as such, it and not the Administrative Toyota - 364 Day Credit Agreement Agent has been designated under this Agreement to carry out certain duties of the Administrative Agent in respect of TCCI.
Parent agrees to enter into an election under Section 85 of the Income Tax Act, Canada ("CANADIAN ITA") whereby it would jointly file a Form T2057 or T2058 with any of the Company's shareholders resident in Canada for purposes of the Canadian ITA that so desire at an amount as determined by the particular shareholder, subject to the limitations set out in the Canadian ITA.
For avoidance of doubt, such Taxes shall not include any withholding Taxes imposed on Buyer including but not limited to (i) the Malaysian Real Property Gains Tax Xxx 0000 and (iii) Section 116 of the Canadian ITA.
The Buyer acknowledges that in connection with the Canadian Pre-Closing Reorganization, Canada Newco will agree with Xxxxxx Canada to make and file joint elections pursuant to the provisions of (i) section 22, subsection 20(24) and section 85 of the Canadian ITA, and the corresponding provisions of any applicable provincial tax statute, in respect of the Canadian Pre-Closing Reorganization and (ii) if applicable, section 167 of the Excise Tax Act (Canada).
For the avoidance of doubt, the Company may, in its sole discretion, include in Canada Newco’s Canadian federal income tax return for its Tax period ending as a result of the sale of the Shares of Canada Newco hereunder, an election pursuant to subsection 256(9) of the Canadian ITA in respect of such taxation year.
No Tax is required to be withheld pursuant to Section 116 of the Canadian ITA (as defined herein) or the Laws of any Canadian province or local jurisdiction or any other foreign jurisdictions as a result of the transfer contemplated by this Agreement.